Michael Alan Jackson and Mary Joy Jackson, et al. - Page 7
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interest. We construe these stipulations as a concession by
respondent that petitioners are entitled to mortgage interest
deductions in these amounts for 2003. Otherwise, petitioners
have not shown that they are entitled to any deductions.
C. Additional Tax for Early Distributions
Respondent determined that Mr. Jackson is liable for a 10-
percent additional tax on his $53 pension distribution in 2000.
Mr. Jackson does not dispute that he received this distribution
from Lockheed Martin Corp. in 2000 as reported on Form 1099-R.
If an individual taxpayer receives any amount from a
qualified retirement plan, including an individual retirement
account, the taxpayer’s tax is increased by 10 percent of the
portion of the amount that is includable in gross income. Secs.
72(t)(1), 4974(c). There are various exceptions to this general
rule, but there are no indications in the record that any of the
exceptions applies, and petitioners raise no arguments with
respect to this issue. We sustain respondent’s determination on
the basis of the record before us. See Cabirac v. Commissioner,
120 T.C. 163, 168 (2003).
D. Additions to Tax and Penalties
The petitions contain no specific allegations or supporting
facts regarding any of the additions to tax that respondent
determined in the respective notices for the years at issue.
Petitioners’ arguments at trial, largely frivolous challenges to
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Last modified: November 10, 2007