Alex B. Rhodes, Jr. - Page 10
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from MBNA Corp., and a taxable distribution of $4,449 from MBNA
Corp. 401K; and (4) in 2003, wage income of $109,395 from MBNA
Technology and a taxable distribution of $4,687 from MBNA Corp.
Although petitioner disputed receiving $4,716 from Texas
Temp, the Court finds that petitioner’s testimony is not
credible. Moreover, petitioner failed to cooperate with
respondent in the preparation of this case. See sec. 6201(d).
For the foregoing reasons, the Court finds petitioner received
$4,716 of wage income from Texas Temp in 2000.
Respondent also determined that the taxable distributions
petitioner received from the Federal Savings Bank in 2000 of $295
and from the MBNA Corp. 401K in 2002 and 2003 of $4,449 and
$4,687, respectively, were early distributions from qualified
retirement plans pursuant to section 72(t)(1). As a result,
petitioner was liable for the 10-percent additional tax on the
distributions he received from these plans. Petitioner does not
dispute that the distributions were from qualified retirement
plans pursuant to section 72(t). Petitioner also does not argue,
and the record is devoid of any evidence which would indicate,
that he is qualified for any exception to section 72(t). For the
foregoing reasons, the Court finds that petitioner is liable for
the 10-percent additional tax on the early distributions from his
qualified retirement plans in 2000, 2002, and 2003.
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Last modified: November 10, 2007