- 4 - 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 arePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011