Steven Rudolph Kaldi - Page 3

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               Petitioner Steven Rudolph Kaldi filed a petition with this             
          Court in response to a Notice of Determination Concerning                   
          Collection Action(s) Under Section 6320 and/or 6330 for 2002.               
          Pursuant to section 6330(d), petitioner seeks review of                     
          respondent’s determination.                                                 
               Some of the facts have been stipulated, and they are so                
          found.  We incorporate by reference the parties’ stipulation of             
          facts and accompanying exhibits.                                            
               At the time that the petition was filed, petitioner resided            
          in Las Vegas, Nevada.                                                       
               Petitioner, an insurance agent, filed his Form 1040, U.S.              
          Individual Income Tax Return, for the taxable year 2002 on July             
          14, 2004, showing an underpayment of income tax.2  The source of            
          the underpayment was a $45,000 distribution from a qualified                
          retirement account.3  He included the $45,000 in his gross income           
          for 2002 and reported the corresponding additional early                    
          withdrawal tax of $4,500 under section 72(t).                               
               Petitioner gave $20,000 of the distribution to his daughter,           
          and put the remaining $25,000 into an investment account managed            

               2  Petitioner had the return prepared by an accountant who             
          had been preparing his taxes since 1980.                                    
               3  Petitioner received a distribution of $117,552 from a               
          qualified retirement account and properly rolled over all but               
          $45,000 of that amount into another qualified retirement account.           
          Petitioner was 57 years of age at the time of the distribution.             

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Last modified: November 10, 2007