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petitioners' claimed bad debt deductions. See Williams v.
Commissioner, T.C. Memo. 1994-560.
It is not clear whether petitioners are also making an
argument that money advanced to the partnerships by ISI should be
viewed as increasing Mr. Bach's basis in the partnerships for
purposes of determining the amount of gain. Any such argument
must be rejected for the same reason we reject petitioners'
argument that they are entitled to an offsetting loss.
Early Distribution From Petitioners' IRA During 1987
Petitioners concede they received an IRA distribution in the
amount of $1,830 from Putnam Option Income Trust during 1987.
Amounts paid or distributed out of an IRA must be included in
gross income "in the manner provided under section 72." Sec.
408(d)(1). A 10-percent tax on "early distributions" generally
applies where a taxpayer receives a distribution from a qualified
retirement plan which is includable in his gross income. Sec.
72(t)(1). Although section 72(t)(2) sets forth certain
exceptions to the 10-percent tax on early distributions,
petitioners have presented no evidence to suggest they fit within
any of these exceptions. Therefore, we find that petitioners are
liable for the 10-percent additional tax under section 72(t).
See Chiu v. Commissioner, T.C. Memo. 1997-199.
Excess Contributions to Petitioners' IRA During 1987
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