Amjad A. Sheikh - Page 3




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          for decision is whether petitioner is liable for the section                
          72(t) 10-percent additional tax relating to an early distribution           
          from a qualified retirement plan.                                           
                                     Background                                       
               In 2003, petitioner, who was less than 59-1/2 years of age,            
          received a $9,776 distribution from a qualified retirement plan.            
          Petitioner reported the distribution on his 2003 Federal income             
          tax return.  On January 23, 2006, respondent sent petitioner a              
          notice of deficiency relating to 2003.  In the notice, respondent           
          determined that petitioner was liable for the section 72(t) 10-             
          percent additional tax because petitioner received an early                 
          distribution from a qualified retirement plan.  On April 18,                
          2006, petitioner, while residing in Joliet, Illinois, filed his             
          petition with the Court and contested the 10-percent additional             
          tax.                                                                        
                                     Discussion                                       
               Section 72(t)(1) imposes a 10-percent additional tax on an             
          early distribution from a qualified retirement plan.  Petitioner            
          contends that he is not liable for the additional tax because of            
          financial hardship.  Section 72(t)(2) lists several exceptions to           
          the additional tax, but there is no exception relating to                   
          financial hardship.  Arnold v. Commissioner, 111 T.C. 250, 255              
          (1998).  Accordingly, respondent’s determination is sustained.              








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