- 7 - is entitled for the year at issue to a deduction for his claimed loss with respect to his radiology practice. We turn now to the 10-percent additional tax under section 72(t) that respondent determined for the year at issue with respect to the retirement plan distributions that petitioner received from Vanguard during that year. Petitioner acknowledges that if the Court were to find that he must include those distri- butions in his gross income for the year at issue, he is liable for the 10-percent additional tax under section 72. We have found that petitioner is required to include in his gross income for the year at issue the retirement plan distributions in question. On the record before us, we find that petitioner is liable for the 10-percent additional tax. We turn finally to the accuracy-related penalty under section 6662(a). Petitioner acknowledges that if the Court were to find that he must include the retirement plan distributions in question in his gross income for the year at issue and that he is not entitled to a deduction for his claimed loss with respect to his radiology practice, he is liable for the accuracy-related penalty under section 6662(a). We have found that petitioner is required to include in his gross income for the year at issue those distributions and that he is not entitled for that year to any such deduction. On the record before us, we find that petitioner is liable for the year at issue for the accuracy-Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011