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Hobson v. Commissioner, T.C. Memo. 1996-272; Grow v.
Commissioner, T.C. Memo. 1995-594; Wheeler v. Commissioner, T.C.
Memo. 1993-561. The language of section 72(t) simply does not
differentiate between voluntary and involuntary withdrawals.
In Larotonda v. Commissioner, 89 T.C. 287 (1987), we held
that where the IRS served a levy against the taxpayer's Keogh
account for payment of an assessed deficiency and the bank
trustee paid the money directly to the IRS, the 10-percent
additional tax was not payable under former section 72(m)(5)(B).
That section differed from current section 72(t), particularly in
that it did not include the list of specific exceptions to tax
set forth in section 72(t)(2). Moreover, in the Larotonda case,
the taxpayer never received the funds and had no opportunity to
avoid the tax by timely reinvestment of the proceeds in another
qualified plan. In Aronson v. Commissioner, 98 T.C. 283, 292
(1992), we applied former section 408(f)(1), similar to former
section 72(m)(5), where taxpayers' receipt of their funds from a
qualified plan was "involuntary" (since their financial
institution had failed and was being liquidated), but the
taxpayers had available an alternative: they could have timely
reinvested or "rolled over" the amounts into another qualified
plan and avoided tax under section 408(d)(3). Since the
taxpayers in Aronson failed to reinvest the distributions in
another qualified plan, we sustained the imposition of the 10-
percent additional tax under former section 408(f)(1). The facts
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