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years in issue. Instead, petitioner testified that she filed
“tax statements”, but she could not recall when she filed the
statements or the nature of those statements. In addition,
petitioner made no estimated tax payments during 1999 or 2000.
On April 8, 2002, respondent prepared substitutes for
returns for petitioner for the years in issue. On April 9, 2003,
respondent sent petitioner notices of deficiency for the years in
issue. Respondent determined that petitioner was liable for
additional taxes of $499 and $5,215 for early distributions from
her IRAs for 1999 and 2000, respectively. Respondent also
determined that petitioner was liable for additions to tax under
sections 6651(a)(1) and 6654(a), as set out above.
In response to the notices of deficiency, petitioner filed a
petition with this Court on July 7, 2003.
OPINION
A. Petitioner Is Liable for a 10-Percent Additional Tax Under
Section 72(t)(1)
Respondent determined that, under section 72(t)(1),
petitioner is liable for a 10-percent additional tax on early
distributions from her IRAs in 1999 and 2000. Petitioner bears
the burden of proving that respondent erred in making this
determination. Rule 142(a).
Section 72(t)(1) imposes a 10-percent additional tax on
early distributions from qualified retirement plans. Qualified
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