Charlotte Marie Scott - Page 11

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          their 2000 adjusted gross income was $4,076.  Thus, petitioner’s            
          expenses paid for medical care in 2000 did not satisfy the                  
          requirements of section 72(t)(2)(B).  Therefore, the                        
          distributions do not fall under the exception of section                    
               Finally, petitioner contends that, because of her financial            
          hardship, the $11,168 should not be subject to the 10-percent               
          additional tax imposed by section 72(t).  Petitioner seeks relief           
          from the 10-percent additional tax imposed on her distributions             
          based on her financial hardship.  There is, however, no hardship            
          exception in the controlling statute, section 72(t).  This                  
          principle has been applied consistently in cases dealing with               
          premature IRA distributions.  See Arnold v. Commissioner, 111               
          T.C. at 255; Gallagher v. Commissioner, T.C. Memo. 2001-34; Deal            
          v. Commissioner, T.C. Memo. 1999-352; Pulliam v. Commissioner,              
          T.C. Memo. 1996-354.  Thus, the IRA distribution received by                
          petitioner is subject to the 10-percent additional tax under                
          section 72(t).                                                              
               Moreover, petitioner alluded that her requests for her                 
          distributions in 2000 were based on reliance of advice given to             
          her by her accountant.  The authoritative sources of Federal tax            
          law are the statutes, regulations, and judicial decisions.                  
          Zimmerman v. Commissioner, 71 T.C. 367, 371 (1978), affd. without           
          published opinion 614 F.2d 1294 (2d Cir. 1979); Green v.                    

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