- 5 -
other, giving petitioner no relief from his condition and causing
him to be very disoriented. Subsequently, petitioner consulted a
second physician, Dr. Gardner, who prescribed only Pamelor,
which, in about six weeks' time, cleared up petitioner's
condition. Petitioner continued to see Dr. Gardner for about two
years, but discontinued seeing him after that time because he
could no longer afford the consultation fees. Petitioner is no
longer on medication. Petitioner regularly exercises to avoid
"putting myself in positions any longer where I can have this
kind of a setback."
Respondent determined an additional tax of $20,880 on the
$208,802 premature distribution from petitioner's IRA.
OPINION
The legislative history accompanying the enactment of former
section 408(f) explains the purpose of what is now section 72(t),
as follows: Premature distributions from IRAs frustrate the
intention of saving for retirement, and section 72(t) discourages
this from happening. S. Rept. 93-383 at 134 (1974), 1974-3 C.B.
(Supp.) 80, 213. Thus, in the event of a distribution to an
individual from his or her IRA before such individual attains age
59-1/2, the individual's tax on the amount distributed is
increased by 10 percent of the total distribution. H. Conf.
Rept. 93-1280, at 339 (1974), 1974-3 C.B. 415, 500.
Section 72(t)(1) and (2) provides in relevant part:
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