-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.
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