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used for retirement purposes, a 10 percent penalty is generally
imposed on IRA distributions made before the taxpayer reaches age
59-1/2. See sec. 72(t). In that regard, an IRA distribution
fits within the category of "a pension or annuity" or "deferred
compensation".4 Petitioner's compensation for the year in issue
therefore does not include the IRA distribution.
In light of the foregoing, petitioner is not entitled to an
IRA deduction in an amount exceeding $271.5
We now turn to some of petitioner's various other concerns.
Petitioner has asked us to consider whether respondent
properly determined the amount of interest imposed under section
6601. We are unable to address this issue. This Court is a
court of limited jurisdiction, and we may exercise jurisdiction
only to the extent expressly authorized by statute. See Judge v.
Commissioner, 88 T.C. 1175, 1180-1181 (1987); Naftel v.
Commissioner, 85 T.C. 527, 529 (1985). This Court's jurisdiction
4 Based on the record, it is not clear whether the IRA
distribution petitioner received was an annuity. To constitute
an annuity, payments must be received in the form of periodic
installments at regular intervals. See sec. 1.72-2(b)(2), Income
Tax Regs. Regardless, even if the IRA distribution did not
constitute an annuity, it would be considered a pension or
deferred compensation benefit.
5 We observe that respondent determined that petitioner was
entitled to an IRA deduction to the extent of his Schedule C
gross income as opposed to his Schedule C "net earnings". See
secs. 219(a), 401(c)(2), 1402(a). We therefore simply sustain
respondent's determination as respondent did not assert an
increased deficiency in this regard. See sec. 6214(a).
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