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should avoid direct exposure to known liver toxins, he could
participate in site surveys with recommended protection, and his
physical examination results were within normal limits.
Petitioner points to communications with IT personnel in
March and April of 2000 where it was determined that he should
not go on certain projects. But also during 2000, he was still
going out on projects. In 2002, when IT went into bankruptcy and
petitioner became unemployed, we cannot say his unemployment was
due to a disability within the meaning of section 72(m)(7).
Certainly none of his doctors stated that he was disabled. It
may well be that he had medical problems, but we are not
convinced that these problems could be expected to result in
death or to be of a long-continued duration to keep him from
engaging in his customary or any comparable substantial gainful
activity.
Petitioners may have been subject to financial hardship
during 2001; there is, however, no exception under section 72(t)
for financial hardship. This principle has been applied
consistently in cases dealing with premature individual
retirement account distributions. See Arnold v. Commissioner,
111 T.C. 250, 255 (1998); Gallagher v. Commissioner, T.C. Memo.
2001-34; Deal v. Commissioner, T.C. Memo. 1999-352; Pulliam v.
Commissioner, T.C. Memo. 1996-354. As the legislative history of
section 408(f), the predecessor to section 72(t), explains, the
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