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Lawrence J. Kaplan, for petitioner.
Christine V. Olsen, for respondent.
OPINION
LARO, Judge: This case is before the Court fully
stipulated. See Rule 122. Petitioner petitioned the Court to
redetermine respondent’s determination of an $84,080 deficiency
in Federal income tax for 1993 and a $16,816 accuracy-related
penalty for negligence under section 6662(a).
After concessions,1 we must decide the following issues with
respect to 1993:
1. Whether petitioner’s gross income includes the entire
$125,000 in distributions he received from his individual
retirement accounts (IRA’s). We hold it does.
1Petitioner concedes the following: (1) His gross income
includes a $64,054 gain on the sale of his home; (2) he may
deduct only $1,476 of the $11,735 claimed for legal and
professional fees paid; (3) he may not deduct the $11,000 claimed
with respect to the purchase of a horse, but may take a Schedule
F, Profit or Loss From Farming, depreciation deduction in the
amount of $393; and (4) he may not deduct the $5,178 claimed for
repair expenses paid. Petitioner also concedes that he should be
taxed on one-half of the $125,000 in IRA distributions he
received in 1993, but he challenges whether he is liable for tax
on the other half.
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