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Respondent determined a deficiency in petitioner’s Federal
income tax of $1,000.11 for the taxable year 2000.
The issue for decision is whether petitioner is liable for
the 10-percent additional tax on an early distribution pursuant
to section 72(t).
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. Petitioner resided in
Hillsborough, California, on the date the petition was filed in
this case.
Charlotte Marie Scott (petitioner) began working for Digital
Equipment Corp. in 1985. Petitioner worked 13 years for Digital
Equipment Corp. until she was laid off in 1998. During her
employment with Digital Equipment Corp., petitioner set up an
Individual Retirement Account (IRA). This IRA was established
through Donaldson, Lufkin and Jenrette Securities Corp. as an
agent for Gruntal and Co., LLC. At the end of her employment,
this account was valued at about $30,000.
After being laid off from Digital Equipment Corp.,
petitioner received unemployment benefits for the remainder of
1998 to April 1999, when she was employed by High Voltage
Engineering Corp. (referred to as Robicon). Petitioner worked
for Robicon from April to October 1999, when she was again laid
off. While with Robicon, petitioner became a member of her
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