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The purpose of the early withdrawal penalty is to prevent
the diversion of IRA funds to nonretirement uses and to recapture
a measure of the tax benefits that have been provided. S. Rept.
99-313, 1986-3 C.B. (Vol. 3) 1, 612-613; H. Rept. 99-426, 1986-3
C.B. (Vol. 2) 1, 728-729; see also Aronson v. Commissioner, 98
T.C. 283, 290-291 (1992) (discussing former sec. 408(f), the
predecessor of sec. 72(t)). The language of section 72(t) does
not differentiate between voluntary and involuntary withdrawals.
Thus, we have held the section 72(t) tax to be applicable where
the taxpayer did not initiate the distribution. Clark v.
Commissioner, 101 T.C. 215 (1993) (pension plan distribution due
to termination of plan); Aronson v. Commissioner, supra (IRA
distribution followed insolvency of financial institution);
Vorwald v. Commissioner, supra. On the other hand, in Larotonda
v. Commissioner, 89 T.C. at 292, we recognized the same
legislative purpose in respect of the addition to tax on
distributions from Keogh plans under section 72(m)(5), but held
that that section did not apply where the proceeds of such a plan
were levied upon to satisfy respondent's income tax levy. We
reaffirmed our holding in Larotonda in Aronson v. Commissioner,
supra at 292, pointing out that in Larotonda: "The IRS notice of
levy triggered the taxable event, and we were concerned that
Congress did not intend the additional tax to apply to such a
situation. Consequently, we ruled for the taxpayers and
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