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Petitioner did not file a Federal income tax return for
2001. Using third-party-payor information, respondent determined
that in 2001 petitioner received wage income of $99,949 from MBNA
and capital gain income of $73 from AXP. Petitioner failed to
make estimated tax payments, other than tax of $43 withheld by
MBNA.
Petitioner did not file a Federal income tax return for
2002. Using third-party-payor information, respondent determined
that in 2002 petitioner received wage income of $99,771 from MBNA
Technology, Inc. (MBNA Technology), capital gain income of $456
from MBNA Corp., and a taxable distribution of $4,449 from MBNA
Corp. 401K Plus Savings Plan (MBNA Corp. 401K). Petitioner
failed to make estimated tax payments, other than tax withheld by
MBNA Corp. 401K of $615. Respondent determined petitioner was
liable for the additional tax of 10 percent on the distribution
from MBNA Corp. 401K pursuant to section 72(t) because it was an
early distribution from a qualified retirement plan.
Respondent received petitioner’s Form 1040, U.S. Individual
Income Tax Return, for 2003 (2003 return) on February 3, 2004.
The 2003 return showed zeros on lines 7 through 22, zero adjusted
gross income (line 33), zeros on lines 35 through 43, zeros on
lines 53 through 59, zero total tax, Federal income tax
withholding of $569, and a claimed refund of $569. Under Rule
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Last modified: November 10, 2007