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BARNES v. COMMISSIONER

Docket No. 3068-92.

67 T.C.M. 2341 (1994)

T.C. Memo. 1994-95

Sanford Ottis Barnes, Jr. v. Commissioner.

United States Tax Court.

Filed March 3, 1994.

Attorney(s) appearing for the Case

Karl Norman Clifford, for the petitioner. William Mark Scott, for the respondent.

Memorandum Opinion

SCOTT, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the calendar year 1988 in the amount of $29,563. The deficiency includes a 10-percent additional tax on early distributions under section 72(t)1 in the amount of $11,341.

The issues for decision are: (1) Whether petitioner, after having within 60 days of a distribution from a qualified pension plan, rolled over the...

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