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.             
          401K.                                                                       
               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