-6-
during 1999, OppenheimerFunds Services (1) distributed $179,558
to petitioner from one of petitioner’s retirement accounts and
(2) received on petitioner’s behalf $1,827 of dividends and
$90,039 from the sale of stock. The records also show that
during 1999, Franklin Templeton Investor Services distributed
$129,074 to petitioner from another of petitioner’s retirement
accounts.4 The records of these two entities support the lion’s
share of unreported income determined by respondent, and we hold
that respondent has sufficiently linked petitioner to the
unreported income. See Hardy v. Commissioner, supra at 1005; cf.
McManus v. Commissioner, supra (sufficient link not found in
absence of adequate evidentiary foundation). Given petitioner’s
failure to disprove respondent’s determination of unreported
income, as modified through concessions, we sustain the
determination as modified.
2. 10-Percent Additional Tax on Early Distributions From IRAs
Section 72(t) generally provides that a taxpayer is liable
for a 10-percent additional tax on early distributions from a
qualified retirement plan such as an IRA. See also sec.
4974(c)(4). In 1999, petitioner received taxable distributions
of $312,029 from her IRAs; of this amount, respondent concedes
that $3,407 was not subject to the 10-percent additional tax.
4 The parties have not explained the $10 difference between
the $129,074 shown in the records of Franklin Templeton Services
and the $129,064 shown in the certified transcripts.
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