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contend that the form that it has chosen should be ignored so
that avoidance or postponement of the tax can be accomplished.”
Strick Corp. v. United States, 714 F.2d 1194, 1206 (3d Cir.
1983).
We conclude that petitioners are liable for the 10-percent
additional tax under section 72(t)(1) on the $12,880.04
distribution from petitioner’s TSP to Villanova University.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011