MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1998 in the amount of $25,000. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year at issue.
The issue for decision is whether petitioner is liable for the 10-percent additional tax under section 72(t) on a $250,000 early distribution from...
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