Michael Alan Jackson and Mary Joy Jackson, et al. - Page 7

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          interest.  We construe these stipulations as a concession by                
          respondent that petitioners are entitled to mortgage interest               
          deductions in these amounts for 2003.  Otherwise, petitioners               
          have not shown that they are entitled to any deductions.                    
          C.  Additional Tax for Early Distributions                                  
               Respondent determined that Mr. Jackson is liable for a 10-             
          percent additional tax on his $53 pension distribution in 2000.             
          Mr. Jackson does not dispute that he received this distribution             
          from Lockheed Martin Corp. in 2000 as reported on Form 1099-R.              
               If an individual taxpayer receives any amount from a                   
          qualified retirement plan, including an individual retirement               
          account, the taxpayer’s tax is increased by 10 percent of the               
          portion of the amount that is includable in gross income.  Secs.            
          72(t)(1), 4974(c).  There are various exceptions to this general            
          rule, but there are no indications in the record that any of the            
          exceptions applies, and petitioners raise no arguments with                 
          respect to this issue.  We sustain respondent’s determination on            
          the basis of the record before us.  See Cabirac v. Commissioner,            
          120 T.C. 163, 168 (2003).                                                   
          D.  Additions to Tax and Penalties                                          
               The petitions contain no specific allegations or supporting            
          facts regarding any of the additions to tax that respondent                 
          determined in the respective notices for the years at issue.                
          Petitioners’ arguments at trial, largely frivolous challenges to            

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