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tax on the $17,422 in early distributions petitioner received
from her annuity and SEP-IRA accounts.
Also, on her 2001 tax return petitioner claimed a section
162(l) ordinary deduction of $1,925, the amount allowable under
section 162(l)(1)(B), relating to the $3,209 in health insurance
premiums paid by petitioner’s law partnership on petitioner’s
behalf.
On January 23, 2004, respondent mailed to petitioner a
notice of deficiency with respect to petitioner’s 2001 individual
Federal income tax in which respondent determined that petitioner
was liable for the section 72(t) 10-percent additional tax in the
amount of $1,742 on the total $17,422 in early distributions
petitioner received in 2001 from her annuity and her SEP-IRA
accounts.
At trial, petitioner stipulated the applicability of the
section 72(t) 10-percent additional tax on the $2,000 early
distribution from her SEP-IRA account.
Petitioner disputes the applicability of the section 72(t)
10-percent additional tax only on the $15,422 in early
distributions petitioner received from her annuity accounts.
OPINION
Generally, under the flush language of section 403(b)
amounts contributed to retirement annuity accounts by tax-exempt
section 501(c)(3) organizations on behalf of their employees are
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