Grajales v. Commissioner - In Grajales v. Comm’r of Internal Revenue, the United States Court of Appeals for the Second Circuit addressed whether the ten percent exaction.
In Grajales v. Comm'r of Internal Revenue, the United States Court of Appeals for the Second Circuit addressed whether the ten percent exaction under Section 72(t) (Exaction) is considered a "tax" or an "addition to tax" within the meaning of Section 6751(c).