Memorandum Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $11,159.73 in petitioners' Federal income tax for the year 1987. The sole issue is whether petitioners' utilization of their individual retirement account (IRA) is a permissible IRA investment or a distribution taxable as income and, consequently, an early withdrawal under section 72(t).
All of the facts were stipulated and are so found.
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