Eugenie Denise Mitchell - Page 3

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               At various times in 2001, due to her financial difficulties,           
          petitioner requested and received $17,422 in early distributions            
          from her four annuity and SEP-IRA accounts, as follows:                     

                  Annuity and SEP       Date of          Amount of                    
                    Accounts          Distribution       Distribution                 
                First                   06/22/01          $ 3,000                     
                Second                  06/22/01          6,000                       
                     Third              06/22/01          5,000                       
                     Fourth             10/01/01          1,422                       
                     SEP-IRA            -–/-–/01           2,000                      
                                                                                    
                Total distributions                       $17,422                     

               As of the end of 2001, petitioner had not attained the age             
          of 59-1/2.                                                                  
               During 2001, petitioner paid a total of $1,809 in                      
          unreimbursed medical expenses, and petitioner’s law partnership             
          paid on petitioner’s behalf health insurance premiums in the                
          amount of $3,209.                                                           
               On August 15, 2002, petitioner timely filed her 2001                   
          individual Federal income tax return on which return petitioner             
          reported the total $17,422 in early distributions petitioner                
          received during 2001 from her annuity and SEP-IRA accounts as               
          taxable income.                                                             
               Petitioner, however, on her 2001 individual Federal income             
          tax return failed to report, and petitioner failed to pay with              
          the filing of her return, a section 72(t) 10-percent additional             







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