Alex B. Rhodes, Jr. - Page 2
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$6,045, $6,248, and $6,465, and under section 6654(a) of $1,297,
$966, $833, and $675, respectively.1
After concessions,2 the issues for decision are: (1)
Whether petitioner received taxable income for the years at
issue; (2) whether petitioner is liable for the additional tax
under section 72(t) for early distributions from retirement
plans; (3) whether petitioner is liable for additions to tax
under section 6651(a)(1) for the years at issue; (4) whether
petitioner is liable for additions to tax under section 6654(a)
for the years at issue; and (5) whether the Court should impose a
penalty against petitioner under section 6673(a).
FINDINGS OF FACT
Some of the facts have been deemed stipulated pursuant to
Rule 91(f) and are so found.3 The stipulation of facts and the
attached exhibits are incorporated herein by this reference.
Petitioner resided in Plano, Texas, when he filed the petition.
At the time of trial, petitioner was 42 years old. During
the years at issue, petitioner was employed with various
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
2 Respondent concedes that petitioner did not receive
capital gain income of $164 from the American Express Certificate
Co. and a taxable distribution of $642 from the American Express
Trust Co. in 2000.
3 Proposed stipulations of fact were deemed established by
the Court’s order on Feb. 27, 2006.
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Last modified: November 10, 2007