Luisa Deal - Page 4




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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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