MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge.
Respondent determined a deficiency of $2,251 in petitioner's Federal income tax for 2001. The issues for decision are:
(1) Whether the unpaid balance of a loan taken by petitioner from her qualified retirement plan in 2000 should be deemed a taxable distribution to petitioner in 2001 that is subject to the 10-percent additional tax under section 72(t) and, if so,
(2) whether petitioner...
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