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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
72(t)(2)(B).
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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