Gregory Scott West - Page 8

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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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