In Fields v. Commissioner, T.C. Memo. 2014-48 (March 19, 2014), the Tax Court determined that a petitioner was liable for a 10 percent additional tax pursuant to Internal Revenue Code Section 72(t)(1), due to an early distribution from her qualified retirement plan. Here’s why. The Distribution Prior to 2010, Jennifer Lynn Fields worked for Wal-Mart and participated in its IRC Section 401(k) retirement plan. In 2010, she received a $7,383 distribution (which ...

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