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10-percent additional tax on an early distribution from a
qualified retirement plan pursuant to section 72(t); and (2)
whether petitioner is liable for the accuracy-related penalty
under section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time she filed the
petition, petitioner resided in Chicago, Illinois.
On February 4, 2000, petitioner received a lump-sum
distribution from Aramark Corporation’s retirement savings plan
of $81,169. Petitioner used the distribution to refinance her
house, pay for her son’s wedding, and make payments on her credit
cards.
Petitioner’s 2000 Federal income tax return (tax return) was
prepared by a professional tax preparer. On her 2000 tax return,
the distribution of $81,169 was reported as taxable income, but
no amount was reported on the line for “Tax on IRAs, other
retirement plans, and MSAs.”
On July 3, 2002, respondent sent petitioner a notice of
deficiency for 2000. Respondent increased petitioner’s computed
tax by an additional 10-percent tax on the premature distribution
received by petitioner from Aramark Corporation’s retirement
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