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Co., 348 U.S. 426, 429 (1955) (quoting Helvering v. Clifford, 309
U.S. 331, 334 (1940)). Section 61 specifically lists pension
income as includable in a taxpayer’s gross income. Sec.
61(a)(11). Proceeds from stock sales are likewise includable in
a taxpayer’s gross income. Thus, the distribution of $42,154
that petitioner received from the Colorado Public Employees
Retirement Association and the $24 in stock proceeds received by
petitioner from United Shareholders Services, Inc. are included
in petitioner’s gross income for 2003. While petitioner alleges
in his petition that he is entitled to reduce this income to its
“net” amount, the record contains no evidence that supports this
allegation.
2. 10-Percent Additional Tax on Early Distributions From IRAs
Section 72(t) generally provides that a taxpayer is liable
for a 10-percent additional tax on early distributions from a
qualified retirement plan. See sec. 4974(c)(4). In 2003,
petitioner received taxable distributions of $42,154 from his
IRA. Petitioner has not alleged or shown that he qualifies for
any exception to the 10-percent additional tax and is thus liable
for the additional tax on this amount.
3. Addition to Tax Under Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax for failure to
file a return when due “unless it is shown that such failure is
due to reasonable cause and not due to willful neglect”. The
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