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work in 1997 at an activity comparable to the one in which he
customarily engaged, and thus he was not disabled as defined in
section 72(m)(7). See also Dwyer v. Commissioner, 106 T.C. 337
(1996); Fohrmeister v. Commissioner, T.C. Memo. 1997-159; Brown
v. Commissioner, T.C. Memo. 1996-421.
Petitioner testified that he contacted the Internal Revenue
Service (IRS) with respect to the 10-percent additional tax and
was informed by an IRS agent that he was not subject to the 10-
percent additional tax. 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.
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. Dixon v. United
States, 381 U.S. 68, 72 (1965); Massaglia v. Commissioner, 286
F.2d 258, 262 (10th Cir. 1961), affg. 33 T.C. 379 (1959). While
it is unfortunate that petitioner may have received unhelpful or
incorrect tax advice from an IRS employee, that advice does not
have the force and effect of law.
Although we are very sympathetic to petitioner’s medical
situation, he has failed to show that he was disabled, as defined
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