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medical treatment since then.
Petitioner testified that he did not seek medical attention
during 1996 through 1998 because he was attempting to secure
employment on a part-time basis and health insurance with no
“annual caps”. He further testified that “unfortunately, if you
keep it anonymous, you have greater chances of getting
employment, and you know, insurance.” Petitioner began working
for American Express in mid-1998. Petitioner works on a part-
time basis, approximately 32 hours per week. American Express
offers health insurance with no “annual caps” and a salary
continuance program under the Family and Medical Leave Act of
1993, Pub. L. 103-3, 107 Stat. 6. Petitioner testified that had
he found a company that would have provided the insurance he was
seeking and the part-time schedule, he would have been able to
work in 1997.
Prior to the year in issue petitioner individually owned an
IRA account. During 1997, petitioner withdrew $38,855 from his
IRA account. Petitioner did not roll over the IRA amounts into
another qualified employee retirement plan or individual
retirement plan. The amount withdrawn was reported on
petitioner’s 1997 Federal income tax return. Although the amount
of the distribution was reported on the return, petitioner did
not compute the 10-percent additional tax due for premature
distribution. Petitioner, who was born on March 7, 1957, was 40
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