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age of 59-1/2 during the year at issue. Petitioner presented no
evidence to show that any of the other exceptions under section
72(t)(2) applied to exclude his 1994 distribution from the 10-
percent additional tax provided for in section 72(t)(1).
Accordingly, the Court holds that petitioner is liable for the
10-percent additional tax on early distributions from qualified
retirement plans under section 72(t) in the amount of $50.
Respondent, therefore, is sustained on this issue.
Decision will be entered
for respondent.
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Last modified: May 25, 2011