The IRS’s determination that a taxpayer had unreported wage and IRA distribution income was upheld. For two years, he’d filed a tax return on time that reported zero income and zero liability. However, he’d received wages from his job as an engineer and also distributions from an IRA. The taxpayer didn’t dispute that he’d received payments, but rather made frivolous arguments that the payments weren’t taxable income and that he wasn’t subject to tax. He also owed the 10% additional tax for taking early withdrawals from a retirement plan. (TC Memo 2018-138)