- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011