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purpose of the 10-percent additional tax was to discourage early
distributions from retirement plans because “Premature
distributions frustrate the intention of saving for retirement”.
S. Rept. 93-383, at 134 (1974), 1974-3 C.B. (Supp.) 80, 213.
Petitioners are therefore subject to the 10-percent additional
tax under section 72(t) on the distribution.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered for
respondent with respect to the
deficiency, and decision will be
entered for petitioner with respect
to the section 6662(a) penalty.
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Last modified: May 25, 2011