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the taxation of individual retirement account
distributions. Question 12 may be applicable.
We suggest that the parties meet during the week
of March 4, 1994 after you have had time to review
these materials. The Court requires the parties to be
prepared for trial as of 10:00 a.m. on March 11. Mr.
Levine is available to meet with you between Monday and
Thursday, March 4 through 7. Unfortunately, he will be
out of town on Friday, March 8, and will not be
available to meet with you on that date.
In paragraphs 5 and 6 of the proposed stipulations,
respondent wrote:
5. The petitioners did not appear to an
examination by the Internal Revenue Service. During
appellate consideration after this case was docketed,
the petitioners presented documentation to the Internal
Revenue Service. Based on this documentation, the
Internal Revenue Service allowed the following amounts
which are conceded for purposes of this case:
Schedule C - Primerica:
Automobile expense - $1,872.00 allowed as one-half
of the expense claimed on the Primerica Schedule C as
what the Internal Revenue Service considered to be a
reasonable approximation.
Supplies - $591.00 allowed of the $2,886.00
claimed on the Primerica Schedule C.
Schedule E:
Expense - $9,250.00 allowed of the $10,908.00
claimed. The petitioners concede the balance of
$1,658.00.
Depreciation - $4,505.00 allowed. The respondent
concedes this adjustment in full.
6. The amounts and adjustments that remain in
issue are as follows:
Schedule C:
Automobile Expense - $1,871.00 for the Primerica
Schedule C.
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