Generally, amounts withdrawn from an individual retirement account (IRA) before age 59-1/2 are subject to an additional 10% tax. Exceptions exist, including when the funds are used for a first-time home purchase. One taxpayer took a distribution to purchase her first home, but the IRS applied the 10% tax. The distribution was taken from the taxpayer’s 401(k) plan, not from an IRA. She argued that the 10% tax shouldn’t be charged because she was a first-time homebuyer and because “individual retirement plan” should include 401(k) plans. The U.S. Tax Court held that the tax did apply because the “plain language” of the tax law showed the exception is only for IRAs. (TC Summ. Op. 2019-19)