2
Respondent determined a deficiency in petitioner’s 1996
Federal income tax in the amount of $1,997.1
The sole issue for decision is whether petitioner is liable
for a 10-percent additional tax under section 72(t)(1) on a
$19,971.19 distribution from two individual retirement accounts
(IRA’s).
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Seattle, Washington.
In 1995, petitioner and Patricia M.L. Booth (Ms. Booth) were
married. In 1996, petitioner was employed as a laborer in a
longshoring yard with Northland Services, Inc. Petitioner
individually owned two IRA accounts with Aetna Life Insurance &
Annuity Co. (Aetna) prior to his marriage with Ms. Booth.
Petitioner and Ms. Booth were divorced in 1998.
During 1996, petitioner testified that he withdrew the full
amount of both IRA accounts at “my wife’s order” so that Ms.
1 The notice of deficiency was addressed to Leslie C. and
Patricia M.L. Booth (Ms. Booth). However, Ms. Booth is not a
party to this action.
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Last modified: May 25, 2011