MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
The issue for decision is whether petitioner is liable under section 72(t) for a 10-percent additional tax on $15,422 that was distributed early from petitioner's retirement annuity accounts.
Unless otherwise indicated, all 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.
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