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From the record, the remaining $57,617.93, which was
deposited into the joint savings and checking accounts, was not
readily traceable. However, on November 28, 2001, the balance in
the joint savings account was $57,878.32.
As stated previously, petitioner and Ms. Glenn reported
pension and annuity income of $165,838 on their joint Federal
income tax return for taxable year 2001. However, they did not
report on their 2001 joint Federal income tax return the 10-
percent early withdrawal additional tax imposed by section 72(t).
Petitioner concedes that the total amount of $165,838 of
pension and annuity income reported on the return is subject to
the 10-percent additional tax under section 72(t) on early
withdrawals. After the date of the notice of deficiency,
petitioner tendered to respondent payment of $8,267,
approximately one-half of the amount of the 10-percent additional
tax.
Petitioner contends that he is not liable for the accuracy-
related penalty pursuant to section 6662(a) with respect to the
underpayment attributable to the unreported 10-percent additional
tax under section 72(t), because the underpayment was a result of
an “honest” mistake by his and Ms. Glenn’s tax return preparer.
In addition, petitioner requests relief pursuant to section 6015
from liability for one-half of the 10-percent additional tax
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