James E. Copley and Cynthia R. Copley - Page 3

          excess of the expenses allowed by respondent; (7) whether                   
          petitioners failed to report capital gain in the amount of                  
          $17,826 for 1989; and (8) whether petitioners are liable for an             
          accuracy-related penalty under section 6662(b)(1) for 1990.  For            
          the purpose of clarity, the facts and legal analysis of each                
          issue will be combined.                                                     
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits are incorporated             
          by this reference.  At the time the petition in this case was               
          filed, petitioner James E. Copley resided in Charleston, West               
          Virginia, and petitioner Cynthia R. Copley resided in Treasure              
          Island, Florida.  References to petitioner are to James E.                  
          Issue 1.  IRA Distribution                                                  
               During 1989 and 1990, petitioner was employed by the U.S.              
          Department of Energy (DOE) in Morgantown, West Virginia, as a               
          project manager.  In or around July 1990, petitioner left the DOE           
          allegedly on account of "whistle-blowing" activities.  At the               
          time of his departure, petitioner was entitled to a gross                   
          distribution from the CSRS of $18,446.72.  On August 13, 1990,              
          petitioner directed that these funds be rolled over into a                  
          Fidelity IRA.  For this transaction, Fidelity charged a                     
          commission of 3 percent of the amount deposited.                            
               On August 20, 1990, the market value of the stock purchased            
          by Fidelity for petitioner's IRA account totaled $17,893.10.  On            

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