Alex B. Rhodes, Jr. - Page 3

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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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