Joyce M. Thomas - Page 10

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         Summary                                                                      
              For the above-stated reasons, we hold that petitioner is                
         liable for:  (1) A 10-percent additional tax under section                   
         72(t)(1) on her IRA distributions; (2) section 6651(a)(1)                    
         additions to tax for all years in issue; and (3) section 6654(a)             
         additions to tax for 1999 and 2000.                                          
              In reaching our holdings, we have considered all arguments              
         made, and, to the extent not mentioned, we conclude that they are            
         moot, irrelevant, or without merit.                                          
              To reflect the foregoing,                                               
                                                 Decision will be entered             
                                            under Rule 155.                           

























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