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limited exclusion is also available for distributions made to an
employee for medical care expenses. See sec. 72(t)(2)(B).
Petitioner's IRA was a qualified retirement plan.
Petitioner did not roll over her IRA distribution and does not
claim to fit within any of the statutory exceptions of section
72(t)(2). Petitioner testified that she was aware of the
provisions of section 72(t) when she filed her 1995 income tax
return but claims that she relied on erroneous advice she
received from the Internal Revenue Service (IRS) when she called
for information to prepare her return.
In sum, petitioner contends that the application of section
72(t) in this case is inequitable because she made a good faith
effort to correctly file her 1995 Federal income tax and relied
on IRS advice.
This Court has previously held that the authoritative
sources of Federal tax law are statutes, regulations, and
judicial case law and not informal IRS sources. See Zimmerman v.
Commissioner, 71 T.C. 367, 371 (1978), affd. without published
opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner, 59
T.C. 456, 458 (1972). Additionally, in order to ensure uniform
enforcement of the tax law, the Commissioner must follow
authoritative sources of Federal tax law and may correct mistakes
of law made by IRS agents or employees. See Dixon v. United
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