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Dianne Crosby and Christine Keller, for respondent.
MEMORANDUM OPINION
HALPERN, Judge: By notice of deficiency dated June 19,
1995, respondent determined a deficiency in petitioner’s Federal
income tax for 1992 of $23,959 and additions to tax for that year
under sections 6651(a)(1) and 6654(a) of $5,916.25 and $1,029.42,
respectively. Unless otherwise noted, all section references are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are (1) whether a pension plan
distribution to petitioner is taxable pursuant to section
402(a)(1) and whether petitioner is liable for a 10-percent
additional tax under section 72(t) on that distribution,
(2) whether petitioner is liable for a 10-percent additional tax
under section 72(t) on a portion of a distribution from an
individual retirement account, and (3) whether petitioner is
liable for the additions to tax. The parties have stipulated
various facts, which we so find. The stipulation of facts filed
by the parties, with accompanying exhibits, is incorporated
herein by this reference. We need find few facts in addition to
those stipulated. Accordingly, we shall not separately set forth
our findings of fact and opinion, and the additional findings of
fact that we must make are contained in the discussion that
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