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Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs,
Insurance Contracts, etc. (Form 1099-R), with respect to each of
those distributions.
On March 3, 1998, petitioner deposited the $131,5552 retire-
ment plan distribution that he received from Vanguard into a
certificate of deposit in his name at American Savings Bank in
Honolulu, Hawaii (Bank). (We shall refer to that certificate of
deposit as petitioner’s American Savings Bank CD.) On March 31
and April 2, 1998, the Bank credited petitioner’s American
Savings Bank CD with interest of $501.71 and $34.60, respec-
tively. On April 6, 1998, petitioner withdrew the entire balance
of $132,092.20 from petitioner’s American Savings Bank CD.
For an undisclosed period of time, petitioner, who received
a medical degree, operated a radiology practice. On May 25,
1997, that practice was closed.
Petitioner timely filed Form 1040EZ, Income Tax Return for
Single and Joint Filers With No Dependents (return), for his
taxable year 1998. That return reported no income and no tax
liability and claimed no prepayment credits.
Respondent issued a notice of deficiency (notice) to peti-
2The actual amount that petitioner deposited into peti-
tioner’s American Savings Bank CD was $131,555.89. One of the
Forms 1099-R that Vanguard issued to petitioner for 1998 showed a
retirement plan distribution of $131,555. The record does not
explain the 89-cent discrepancy between the $131,555.89 deposited
into the American Savings Bank CD and the $131,555 retirement
plan distribution shown in Form 1099-R issued to petitioner.
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