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petitioners’ situation. Rather, this Court has repeatedly held
that we are bound by the list of statutory exceptions set forth
in section 72(t)(2). Arnold v. Commissioner, 111 T.C. 250, 255
(1998); Schoof v. Commissioner, 110 T.C. 1, 11 (1998); Clark v.
Commissioner, 101 T.C. 215, 224-225 (1993); Swihart v.
Commissioner, T.C. Memo. 1998-407. Although the Court is
sympathetic to petitioners’ position, we are constrained to
sustain respondent’s determination on this issue. Reviewed and
adopted as the report of the Small Tax Case Division.
To reflect our disposition of the disputed issue, as well as
petitioners’ concession, see supra note 2,
Decision will be entered
for respondent.
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Last modified: May 25, 2011