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1995 and 1996, petitioner, as a representative of SEC,
contributed his services as a consulting engineer to nonprofit
organizations such as Christian Fellowship Ministries. Neither
SEC nor petitioner billed or received any money for such
services. SEC did not receive taxable income during the years in
issue, nor did SEC pay petitioner any sums as either salary or
self-employment income during the years in issue.
Petitioner maintained an account at Charles Schwab titled in
his name “UTA Charles Schwab & Co Inc, SEP-IRA DTD 11/20/93".
Contributions were made to the account in the amounts of $27,500
for 1995 and $30,000 for 1996. Petitioner also paid $3,079 and
$4,570 for self-employed health insurance for 1995 and 1996.
Petitioner’s father, Peter J. Spuler, Sr. (Mr. Spuler), died
in 1995. During that year petitioner received a distribution in
the amount of $10,906 from Mr. Spuler’s estate representing
petitioner’s share of an IRA owned by Mr. Spuler and held by the
South Jersey S&L Association. The record is unclear as to
whether petitioner was listed as a beneficiary of the IRA and/or
whether the distribution was paid directly to petitioner or
passed through the estate. Mr. Spuler’s will provided that his
estate would be liable for all Federal, State, and other taxes
arising from the transfer of property under the will.
Petitioner received automatic extensions to file his 1995
and 1996 Federal income tax returns. The due date of the 1995
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