MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $2,280 in petitioners' Federal income tax for 1997. The issues for decision are whether the distribution to Andrew P. Gallagher (petitioner) from an individual retirement account (IRA) was includable in petitioners' gross income and whether that same distribution was subject to the 10-percent additional tax imposed by section 72(t).
Unless otherwise indicated...
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