Kurt Steven and Juanita Fay Urban - Page 15

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          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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