William Anthony Knipp - Page 4

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          of the date of trial.  He was not disabled and did not use the              
          distribution to pay for qualified higher education expenses or to           
          purchase his first home.  See sec. 72(t)(2)(A), (E), (F).  At               
          trial, petitioner presented no evidence that he qualified for any           
          of the exceptions enumerated in section 72(t)(2).  Accordingly,             
          we hold that petitioner is liable for the 10-percent additional             
          tax of $2,352 pursuant to section 72(t)(1).                                 
               To reflect the foregoing,                                              

                                                   Decision will be entered           
                                              for respondent.                         




























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