Jay Andrew Reindl - Page 5




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          hardship.1  Arnold v. Commissioner, 111 T.C. 250, 255 (1998);               
          Thompson v. Commissioner, T.C. Memo. 2007-327; Cole v.                      
          Commissioner, T.C. Memo. 2006-44; Gallagher v. Commissioner, T.C.           
          Memo. 2001-34; Deal v. Commissioner, T.C. Memo. 1999-352; Duffy             
          v. Commissioner, T.C. Memo. 1996-556; Pulliam v. Commissioner,              
          T.C. Memo. 1996-354.                                                        
               Petitioner also argues that his ignorance of the 10-percent            
          additional tax should except him from liability to pay it.                  
          However, as a general rule, taxpayers are charged with knowledge            
          of the tax laws.  Harrington v. Commissioner, 93 T.C. 297, 314              
          (1989).                                                                     
               We conclude that under section 72(t) petitioner is liable              
          for the 10-percent additional tax with respect to his $37,200               
          early IRA distribution.                                                     
               To reflect the foregoing,                                              
                                                Decision will be entered              
                                           for respondent.                            






               1 Not applicable to petitioner’s financial hardship (and not           
          effective before Dec. 21, 2005) is a statutory exception to the             
          imposition of the additional tax under sec. 72(t) applicable to             
          certain victims of hurricanes Katrina, Rita, and Wilma.                     
          Sec. 1400Q(a)(1), (4)(A); Gulf Opportunity Zone Act of 2005,                
          Pub. L. 109-135, sec. 201(a), 119 Stat. 2596.                               







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