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duration. An individual shall not be considered
to be disabled unless he furnishes proof of the
existence thereof in such form and manner as the
Secretary may require.
Respondent argues that petitioners’ claim that Mrs. Jacobsen was
disabled is inconsistent with her performance of services in
Mr. Jacobsen’s business during 1997.
Mr. Jacobsen explained that Mrs. Jacobsen’s activities in
relation to his business were therapeutic, and we do not believe
that a performance of office and administrative tasks at home is
inconsistent with disability resulting from heart disease. We
disallowed deductions for car and truck expenses partly because
the substantial expenses that were claimed to be business related
were unreasonable during the time that petitioners were dedicated
to the care of Mrs. Jacobsen. We are satisfied that she was
disabled for purposes of section 72(t) and that petitioners are
not liable for the additional tax on the distribution from her
retirement plan.
Mr. Jacobsen, however, relies on section 72(t)(2)(iv), with
respect to the distribution from his retirement plan, claiming
that the payments that he received over a period of years were
substantially equal. Under Internal Revenue Service Notice
89-25, Q&A No-12, 1989-1 C.B. 662, 666, there are three methods
that may be used to calculate substantially equal annual periodic
payments: (1) Any method that would be acceptable for purposes
of calculating the minimum distribution required under section
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