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companies as a data communication network designer and engineer.
For each year at issue, petitioner gave his employers Forms W-4,
Employee’s Withholding Allowance Certificate, certifying he was
exempt from Federal income tax withholding.
Petitioner did not file a Federal income tax return for
2000. Using third-party-payor information, respondent determined
that in 2000 petitioner received: (1) Wage income of $12,733,
$10,595, $4,716, $44,250, $14,271, and $9,279, from Metro
Information Services, Ajilon LLC, Texas Temp Limited Partnership
(Texas Temp),4 MBNA Hallmark Information Services (MBNA), SCB
Computer Technology, Inc., and CCC, Inc., respectively; (2)
capital gain income of $412 and $164 from AXP Blue Chip Advantage
Fund (AXP) and American Express, respectively; and (3) a taxable
distribution of $295 from his individual retirement account with
Federal Savings Bank. Petitioner failed to make estimated tax
payments, other than tax withheld of $59 by Federal Savings Bank.
Respondent determined petitioner was liable for the additional
tax of 10 percent on the distribution from Federal Savings Bank
pursuant to section 72(t) because it was an early distribution
from a qualified retirement plan.
4 On Feb. 10, 2006, petitioner filed with the Court
Petitioner’s Reply to Respondent’s Reply to Petitioner’s Response
to Order to Show Cause, in which he asserted that he had never
provided services for Texas Temp.
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Last modified: November 10, 2007