MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1990 in the amount of $4,047. The deficiency includes the 10-percent additional tax imposed by section 72(t) on early distributions from qualified retirement plans...
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