DAWSON, Judge

: This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and Rules 180, 181, and 183.¹

The Court agrees with and adopts the

the recipient of the balance to the credit of an employee which becomes payable to the recipient--(i) on account of the employee's death, (ii) after the employee attains age 59¹ /² , (iii) on account of the employee's separation from the service, or (iv) after the employee has become disabled * * * from a trust which forms a part of a plan described in section 401(a) and which is exempt from tax under section 501 * * * . For purposes of this subsection, the balance to the credit of the employee does not include the accumulated deductible employee contributions under the plan (within the meaning of section 72(o)(5)). [Emphasis added.]

There is no dispute that the Retirement System is a plan described in section 401(a) and that the trust forming a part thereof is exempt from tax under section 501. Moreover, there is no dispute that the Transfer Refund distribution was made within a single taxable year. Therefore, we must decide (1) whether petitioner received the "balance to the credit" when he received the Transfer Refund and (2) whether the Transfer Refund became payable to petitioner "on account of the employee's separation from the service".

In support of her determination that petitioner did not receive the "balance to the credit" when he transferred from the Retirement System to the Pension System, respondent relies on the fact that petitioner's years of creditable service under the Retirement System carried over to the Pension System, see Md. Ann. Code, art. 73B, sec. 144(4) (1988), and on the related fact that those years of service increased the monthly annuity benefit to which petitioner is entitled.

System is calculated by taking into account petitioner's "average final compensation" and petitioner's years of "creditable service". Md. Ann. Code, art. 73B, sec. 145(2) (1988). Because section 402(e)(4)(C) requires that we treat the Retirement System and the Pension System as a single pension plan, we conclude that, by transferring from the Retirement System to the Pension System, petitioner did not forfeit his right to a future monthly annuity, but simply elected to receive an initial single payment to be followed by a reduced monthly annuity. Effectively, petitioner's transfer allowed him to receive the "balance to the credit" in two parts, an initial single payment to be followed by a reduced monthly annuity, based on all of his years of creditable service, and on his salary during those years. See Green v. Commissioner , T.C. Memo. 1994-340.

The testimony of petitioner at trial reflects the foregoing. Thus:

Q: * * * And you transferred to that Pension

System from the Retirement System in 1990; is that correct?

A: Yes, sir.

Q: Okay. Do you know how your pension annuity is currently calculated?

A: It's calculated on your number of years in service and what your salary was.

Q: Okay. And do you know that your annuity was calculated based on all of the years of service that you had, the entire time you've been employed with the State of Maryland?

A: Yes, sir.

Q: So that those years would include the years of which you are a member of the Retirement System; is that correct?

A: Yes.

Q: Thank you. And do you also know that the benefit in particular that you are now receiving under the Pension System is calculated based on all of those years? It's stipulated in paragraph 18, that the benefit you're receiving in the Pension System is calculated by including the years of creditable service recognized under the Retirement System. That's your understanding of what you're receiving now, correct? A: Yes, sir.

In an effort to counter the foregoing, petitioners contend that IRS Publication 575 (Pension and Annuity Income) and IRS Publication 590 (Individual Retirement Arrangements), as well as explications of those publications by the Maryland State Retirement and Pension Systems, support petitioners' position that the Transfer Refund constitutes a "lump sum distribution". This contention, however, is contrary to the well-established principle that the authoritative sources of Federal tax law are the statutes, regulations, and judicial decisions, and not informal publications authored by the Internal Revenue Service or others. Zimmerman v. Commissioner , 71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner , 59 T.C. 456, 458 (1972). A fortiori, explications of such publications by a Maryland State agency are Petitioners complain that neither the taxable amount of the Transfer Refund nor the amount of petitioner's previously taxed contributions has ever been precisely determined. Here we can In view of the foregoing, we hold that the Transfer Refund did not constitute a lump-sum distribution within the meaning of section 402(e)(4)(A) because petitioner did not receive the "balance to the credit" when he transferred from the Retirement distribution issue that this Court has reached. Sites v. United States , 75 AFTR 2d 95-2504, 95-1 USTC par. 50,280 (D. Md. 1995). The final paragraph of the district court's analysis deserves to be quoted:

The Court believes that the statutory analysis and reasoning of Hoppe [ v. Commissioner , T.C. Memo. 1994635] is sound. Because the Retirement System and Pension System were both maintained by Taxpayer's employer, the State of Maryland, they are to be aggregated for purposes of determining the "balance to the credit" of an employee under section 402(e)(4)(A). Whereas Taxpayer received a refund of his contributions and the accumulated interest, his service credits were transferred to and remained within the Pension System. * * * By choosing to transfer to the Pension System, * * * [Taxpayer] opted * * * to receive a refund of his contributions and accumulated interest along with reduced annuity payments in the future . Thus, in effect, Taxpayer elected to receive the "balance to the credit" of his account in two-parts: the refund payment and the future annuity payments. Consequently, he did not receive the "balance to the credit" of his account on * * * [the Transfer Refund date]. Id.

[75 AFTR 2d 95-2504, 95-1 USTC par. 50280 at 88,031].

Section 72(t) Additional Tax Issue

We turn next to respondent's determination that petitioners are liable for the 10-percent additional tax imposed by section 72(t).

Section 72(t) provides for a 10-percent additional tax on early distributions from qualified retirement plans. Subsection (1), which imposes the tax, provides in relevant part as follows: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * * the taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income.

Even though the result we reach here may seem harsh to petitioners, we may not ignore the plain language of the statute and, in effect, rewrite it in order to achieve what might be viewed by them as the more equitable result. See Hildebrand v. Commissioner , 683 F.2d 57, 58 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Zadan v. Commissioner , T.C. Memo. 1993-85. After all, the power to legislate is exclusively the power of Congress and not of this Court or any other. See Iselin v. United States , 270 U.S. 245, 250 (1926).

In view of the foregoing, we sustain respondent's determination that petitioners are liable for the 10-percent additional tax imposed by section 72(t). See O'Connor v. Commissioner , T.C. Memo. 1994-170; Wheeler v. Commissioner , T.C.

Memo. 1993-561; cf. Dorsey v. Commissioner

, T.C. Memo. 1995-97;

Brown v. Commissioner

, T.C. Memo. 1995-93.

Interest

Finally, having concluded that petitioners are liable for the deficiency in income tax, including the 10-percent additional tax imposed by section 72(t), we address petitioner's contention that they should be relieved of liability for interest on the deficiency.

Petitioners impressed the Court as honest and conscientious taxpayers. Unfortunately, they experienced some frustration during the examination of their 1990 income tax return. Although the Court can appreciate petitioners' frustration, we must nevertheless note that matters involving interest do not, as a general rule, fall within the scope of this Court's jurisdiction. Perkins v. Commissioner , 92 T.C. 749, 752 (1989); LTV Corp. v.

Commissioner

, 64 T.C. 589, 597 (1975); see sec. 6404(e); Marine v. Commissioner , 92 T.C. 958, 994 (1989), affd. without published opinion 921 F.2d 280 (9th Cir. 1991); 508 Clinton St. Corp. v. Commissioner , 89 T.C. 352 (1987). Although there are certain narrowly defined exceptions to this rule, none of them apply in this case. See, e.g., sec. 7481(c); Bax v. Commissioner , 13 F.3d 54 (2d Cir. 1993). In short, it is simply not within our power in this case to relieve petitioners from any part of the interest on the deficiency that will be due.