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the time limit imposed by law.
Since the distribution was funded by petitioner’s own
contributions and matching contributions by his former employer,
petitioner argues that the additional tax should not be applied
to these funds even if it would have been applied to a
distribution consisting of the earnings on the funds contributed.
Unfortunately, the tax laws make no distinction, see sec.
61(a)(11), and the 10-percent additional tax applies equally to
both sources of funds.
In closing, we think it appropriate to observe that we found
petitioner to be a very conscientious taxpayer who takes his
Federal tax responsibilities seriously. The Tax Court, however,
is a court of limited jurisdiction and lacks general equitable
powers. Commissioner v. McCoy, 484 U.S. 3, 7 (1987); Hays Corp.
v. Commissioner, 40 T.C. 436, 442-443 (1963), affd. 331 F.2d 422
(7th Cir. 1964). Consequently, our jurisdiction to grant
equitable relief is limited. Woods v. Commissioner, 92 T.C. 776,
784-787 (1989); Estate of Rosenberg v. Commissioner, 73 T.C.
1014, 1017-1018 (1980). This Court is limited by the exceptions
enumerated in section 72(t). See, e.g., Arnold v. Commissioner,
111 T.C. 250, 255-256 (1998); Schoof v. Commissioner, 110 T.C. 1,
11 (1998). Although we acknowledge that petitioner used his
distributions for entirely reasonable purposes, absent some
constitutional defect we are constrained to apply the law as
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