- 16 - taxable income by $150,000.11 As corollaries to this determination, respondent also determined that petitioners are liable for: (1) The additional tax under section 72(t) for a premature distribution from the Retirement System; (2) the excise tax under section 4980A for an excess distribution from the Retirement System; and (3) the excise tax under section 4973 for an excess contribution to petitioner's IRA with First National.12 Petitioners' 1990 Income Tax Return On their income tax return for 1990, petitioners reported taxable interest in the total amount of $154,613. Of this amount, $150,000 represented a distribution from petitioner's IRA with First National, which petitioners characterized as an early withdrawal. The balance represented interest income from unrelated bank accounts. 11 The notice of deficiency, which was issued by respondent's Appeals Office in Baltimore, Maryland, states as follows: Your gross income has been increased to include the amount of $150,000 you received as payment from your qualified retirement plan because you received the payment before you reached aged [sic] 59 1/2 or became disabled. Accordingly, taxable income is increased $150,000. Respondent repeatedly cross-referenced the foregoing paragraph by way of explanation for most of the other adjustments made in the notice of deficiency. 12 See supra note 6 regarding respondent's concession of the excise taxes as to petitioner Patricia M. Brown.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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