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the exceptions set forth in section 72(t)(2) apply in this case.
Thus, the early distributions made by petitioner are subject to
the additional 10-percent tax under section 72(t)(1).
In reaching our holding, we have considered all arguments
made by the parties, and to the extent not mentioned above, we
find them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011