Peter Spuler, Jr. - Page 6

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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,            
               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           

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