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thereof into an IRA with First National Bank of Maryland (First
National).
Petitioner's IRA Distribution
Sometime after petitioner had effected the $150,000 rollover
of his Transfer Refund, petitioner's former supervisor informed
petitioner that the Transfer Refund might not qualify for tax-
free rollover treatment. Accordingly, on or about August 8,
1990, petitioner withdrew $157,174 from his IRA with First
National. At the time that petitioner received this
distribution, he had not quite attained the age of 53.
Petitioner's Health And His Employment
Petitioner has had a history of health problems. When he
was about 1 year old, petitioner contracted polio and suffered
severe atrophy of his right leg. As a consequence, petitioner
has suffered severe degenerative joint disease of the spine and
left knee.
The strain on petitioner's body, and in particular the
strain on petitioner's right leg and spine, has been exacerbated
by petitioner's obesity. His weight has exceeded 300 pounds for
substantial periods of his life. In October 1989 his weight
exceeded 290 pounds.
Petitioner developed severe lower back problems, which
caused considerable pain, because of the polio-induced atrophy of
his right leg. In 1977 petitioner was forced to undergo back
surgery, and vertebrae in his spine were fused in order to manage
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