FRIEDMAN, Senior Circuit Judge.
For many years the Internal Revenue Code has provided that if the owner of an Individual Retirement Account ("IRA") withdraws all or part of it for an impermissible (non-retirement related) purpose or before reaching a certain age, there will be a ten percent tax on the withdrawal. In the summer of 1997 Congress created a second kind of IRA (effective January 1, 1998) — the so-called Roth IRA — and provided that ordinary...
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