James Christian Jensen - Page 2

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               The issues remaining for decision are:                                 
               (1) Is petitioner required to include in his gross income              
          for the year at issue certain distributions from his retirement             
          plan (retirement plan distributions) that he received during that           
          year?  We hold that he is.                                                  
               (2) Is petitioner entitled for the year at issue to a                  
          deduction for a claimed loss with respect to his radiology                  
          practice?  We hold that he is not.                                          
               (3) Is petitioner liable for the year at issue for the 10-             
          percent additional tax under section 72 with respect to his                 
          retirement plan distributions that he received during that year?            
          We hold that he is.                                                         
               (4) Is petitioner liable for the year at issue for the                 
          accuracy-related penalty under section 6662(a)?  We hold that he            
          is.                                                                         
                                  FINDINGS OF FACT                                    
               Many of the facts have been stipulated and are so found.               
               At the time he filed the petition in this case, petitioner             
          resided in Henderson, Nevada.                                               
               During 1998, petitioner received from Vanguard Fiduciary               
          Trust Co. (Vanguard) two retirement plan distributions in the               
          amounts of $131,555 ($131,555 retirement plan distribution) and             
          $42,704 ($42,704 retirement plan distribution), respectively.               
          Vanguard issued to petitioner Form 1099-R, Distributions From               






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