- 7 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007