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Petitioner filed Federal income tax returns for the taxable
years prior to 1993, but she did not file Federal income tax
returns for the taxable years ended December 31, 1993 or 1994.
Petitioner did, however, file an extension with the Internal
Revenue Service (IRS) for the 1993 taxable year. Petitioner
chose not to file 1993 or 1994 Federal income tax returns because
she ran out of money and was employed only part-time during those
years. Petitioner also decided not to file tax returns for those
years in protest over a dispute she was having with the IRS
concerning some FICA overwithholding by her former employer, TWA,
for the 1988 taxable year. In November of either 1992 or 1993,
petitioner consulted Mr. Henschel, a tax attorney, about filing a
Federal income tax return for the 1993 year.
During the 1993 taxable year, petitioner received $35,000 in
taxable distributions from two qualified individual retirement
accounts (IRA’s), and, during the 1994 taxable year, petitioner
received another taxable distribution in the amount of $8,717.32
from one of her qualified IRA’s. No portion of the 1993 or 1994
distributions was rolled over into another plan or account, was
made on or after the date on which petitioner attained the age of
59-1/2, was made to petitioner after attaining the age of 55
years, or was made pursuant to a qualified domestic relations
order. Petitioner did not incur any qualified higher education
expenses in 1993 or 1994 and was not a first-time home buyer in
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