5
the IRS apparently determined a "fine" or "penalty" in regard to
the $4,172 amount.
In contesting all "unlawful fines and/or penalties" in his
petition to this Court, petitioner is inviting this Court to
consider all of the 1993 "fines and/or penalties" determined by
the IRS. We decline to do so.
Petitioner has not contested on any specific ground
respondent's determination that he is liable for a 10-percent
additional tax on his 1993 IRA distribution. Since petitioner
fails to qualify for any of the statutory exceptions under
section 72(t)(2), we hold that petitioner is liable for the
10-percent additional tax on distributions from a qualified
retirement plan for 1993 as provided in section 72(t)(1).
Respondent is sustained on this issue.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5
Last modified: May 25, 2011