-20- Accordingly, petitioners bear the burden of proving that respondent's determination in the notice of deficiency is erroneous. See Rule 142(a). In order for petitioners to prevail, they must prove that the distribution of $25,000 made in 2002 by petitioner's IRA in the OCTFCU is part of a series of substantially equal periodic payments, as described by section 72)(t)(2)(A)(iv). See Arnold v. Commissioner, 111 T.C. 250, 255 (1998). For the reasons discussed above, we find that petitioners have not met their burden of establishing that the subject distribution of $25,000 is part of a series of substantially equal periodic payments, as described by section 72)(t)(2)(A)(iv). On the basis of the foregoing, Decision will be entered for respondent.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21Last modified: March 27, 2008