Ronny H. and Charlotte A. Schmalzer - Page 3

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          to time, petitioner made various deposits to and withdrawals from           
          the IRA account.  The record reflects that petitioner made the              
          following deposits to and withdrawals from the IRA account:                 
                         Date             Deposits     Withdrawals                    
                    Dec. 8, 1989        $50                                           
                    Dec. 15, 1989       50                                            
                    Dec. 22, 1989       50                                            
                   Dec. 29, 1989       50                                            
                    Jan. 5, 1990        50                                            
                    Apr. 18, 1990       1,100                                         
                    May 4, 1991                        $1,400                         
                    May 22, 1991        2,000                                         
          In 1992, petitioner made the following withdrawals from the IRA             
          account:                                                                    
                    Jan. 29, 1992                 $1,000                              
                    Apr. 6, 1992                       2,000                          
                    July 21, 1992                      2,000                          
                    Dec. 7, 1992                         1,100                        
                    Total                              6,100                          
          On December 31, 1992, there was a balance in the IRA account of             
          $1,374.53.                                                                  
               Petitioners contend that they did not claim any deductions             
          for contributions to petitioner’s IRA account on their Federal              
          income tax returns.  Petitioners’ Federal income tax returns for            
          the years 1985 and 1986 are not part of the record.  Petitioners’           
          1987 return, with the exception of the first page, is part of the           
          record, but in the absence of the first page, it is not possible            
          to determine whether a deduction was claimed for an IRA                     








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