Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 21

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          an annuity, including a retirement plan, where an exception does            
          not apply.  Sec. 72(a).  Additionally, unless an exception                  
          applies, there is a 10-percent additional tax on early                      
          withdrawals from qualified retirement plans.  Sec. 72(t)(1).  The           
          Michoff, Srs., have offered no testimonial or documentary                   
          evidence to contradict their stipulations or to support an                  
          exclusion.  Respondent's determination is therefore sustained on            
          this issue.                                                                 
          Unreported Income--Michoff, Srs.                                            
               Revenue Agent Anita Russell, using a bank deposits analysis,           
          determined that the Michoff, Srs., received unreported taxable              
          income in the 1986, 1987, 1988, and 1989 tax years.  Based on               
          this analysis, respondent, after concessions, argues that the               
          Michoff, Srs., had unreported income for those years in issue in            
          the amounts of $75,740, $10,107, $10673, and $4,600,                        
               The Michoff, Srs., purchased a cashier's check from El                 
          Dorado Savings and Loan Association for the purpose of purchasing           
          real property in the amount of $64,500 in the 1986 tax year.                
               The Michoff, Srs., made deposits in the amounts of $11,240             
          and $10,107 which are in issue to their El Dorado Savings and               
          Loan Association account in the 1986 and 1987 tax years,                    
          respectively.  These deposits do not make up the total amount               
          deposited into this account in these years.                                 

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