William L. Reese (1997)

T.C. Memo. 1997-346

UNITED STATES TAX COURT WILLIAM L. REESE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18442-95. Filed July 29, 1997.

1. Held: P is taxable on a pension plan distribution because he failed to roll over that distribution within the 60-day period prescribed by sec. 402(a)(5)(C), I.R.C. Held, further, P is liable for a 10-percent additional tax under sec. 72(t), I.R.C., on that distribution. 2. Held, further, P is liable for a 10-percent additional tax under sec. 72(t), I.R.C., on a portion of a distribution from an individual retirement account. 3. Held, further, sec. 6651(a)(1), I.R.C., addition to tax for failure to file timely return sustained. 4. Held, further, sec. 6654(a), I.R.C., addition to tax for failure to pay estimated tax sustained.

William L. Reese, pro se.

Dianne Crosby and Christine Keller, for respondent.

MEMORANDUM OPINION HALPERN, Judge: By notice of deficiency dated June 19, 1995, respondent determined a deficiency in petit...

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