- 7 - 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”. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011