William E. Levesque - Page 6




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          he retired.  Rahill calculated that petitioner's annual pension             
          benefit was $22,038.37 ($36,730.62 x 60%).  His monthly pension             
          benefit was $1,836.53.                                                      
               On September 8, 1992, Joyce wrote a letter to Benefit Plan             
          Services of State Street Bank & Trust Co. about petitioner's                
          retirement, stating:                                                        
               Mr. William E. Levesque has retired from the City of                   
               Pawtucket effective September 4, 1992.                                 
               Mr. Levesque is entitled to a partial check in the                     
               amount of $1,591.72 for the month of September only and                
               all subsequent checks will be for the full pension                     
               amount of $1,836.53.                                                   
               Please forward Mr. Levesque's pension checks to:                       
                                  119 Hunts Avenue                                    
                                   Pawtucket, RI  02861                               
               Mr. Levesque's monthly pension amount is $1,836.53.  He                
               will receive a cost of living every September 1st of                   
               1.5%.  Mr. Levesque has elected to have no Federal or                  
               State Tax deductions from his monthly pension check.                   
               If you have any questions pertaining to this                           
               correspondence, please contact this office.                            
               In 1992, petitioner received pension payments from Pawtucket           
          totaling $7,101.  That amount equaled 60 percent of his pay from            
          his retirement date to December 31, 1992.                                   
          C.   Petitioner's Tax Return                                                
               Petitioner timely filed his 1992 Federal income tax return             
          in which he reported income and deductions for the taxable year             
          1992 using the cash receipts and disbursements method of                    
          accounting.  Petitioner attached a copy of Form 1099-R to his               
          1992 Federal income tax return.  It showed that he had received             
          the $7,101.  Petitioner did not include any of that amount in his           

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