MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge:
Respondent determined a deficiency in petitioner's Federal income tax (tax) for 1995 in the amount of $16,204. The issues remaining for decision are:
(1) Is petitioner required to include in his gross income for 1995 the distributions that he made during that year from his individual retirement accounts (IRA's)? We hold that he is.
(2) Is petitioner liable for the 10-percent additional...
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