MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge.
Respondent determined a deficiency in petitioner's Federal income tax of $24,593 and an additional tax of $4,397.87 pursuant to section 72(t) for the taxable year 1999. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions by...
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