- 14 -
proper place for a consideration of petitioner’s complaint is the
halls of Congress, not here.” Hays Corp. v. Commissioner, supra
at 443.
Therefore, we conclude that $14,284 of petitioners’ IRA
distribution is subject to the additional tax under section
72(t). Accordingly, we sustain respondent’s determination on
this issue to that extent.
C. Conclusion
We have considered all of the other arguments made by
petitioners, and, to the extent that we have not specifically
addressed those arguments, we conclude them to be without merit.8
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issues, as well
as respondent’s concession,
Decision will be entered
under Rule 155.
8 Petitioners at trial suggested obliquely that the
exception for medical expenses under sec. 72(t)(2)(B) might also
apply. Petitioners, however, did not present any evidence
whatsoever in support of this contention.
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