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and 1996 returns as extended were August 15, 1996, and August 15,
1997, respectively. Petitioner’s 1995 and 1996 tax returns were
received by respondent on August 21, 1996, and October 22, 1997,
respectively.
Respondent mailed a notice of deficiency to petitioner on
February 12, 1999. The notice determined that petitioner failed
to report income of $10,906 in 1995 received as a distribution
from Mr. Spuler’s IRA. The notice also disallowed petitioner’s
deductions for contributions to a simplified employee pension
plan and payments for self-employment health insurance, as
petitioner failed to satisfy the requirements of each deduction.
Respondent also determined that petitioner was liable for an
addition to tax for failure to file a timely return under section
6651(a)(1) and for the negligence penalty under section 6662(a)
for each of the taxable years 1995 and 1996.
After the trial of this case, the Court held a
teleconference with the parties. The Court expressed concern
over the inconclusive evidence regarding the IRA distribution.
The Court provided petitioner an opportunity to submit additional
documents regarding the IRA. We reopened the record and admitted
into evidence a letter from petitioner and a copy of Mr. Spuler’s
will.
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