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Internal Revenue Service. In 1998, petitioner received $247 in
interest from Fulton Bank.
In 1997, petitioner received a $20,356 distribution from his
pension fund at ECS.2 In 1998, petitioner received distributions
of $11,000 from an individual retirement account (IRA) that he
maintained with Vanguard Fiduciary Trust. Also in 1998,
petitioner received a $2,534 distribution from an IRA that he
maintained with Warburg Pincus International Equity Fund.3
Petitioner submitted to respondent a Form 1040, U.S.
Individual Income Tax Return, dated April 14, 1998, for his 1997
taxable year. Petitioner entered zeros on line 7 for wages and
salaries, line 22 for total income, lines 32 and 33 for adjusted
gross income, line 38 for taxable income, line 39 for tax, and
line 53 for total tax.4 Attached to the Form 1040 is a two-page
document in which petitioner explains his position regarding his
entering zeros on that form in which he argues, inter alia, that
2A Form 1099-R, Distributions from Pensions, Annuities,
Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts,
etc., listing sheet for petitioner’s distribution shows a gross
distribution of $20,356.05 and a taxable amount of $4,000.
3Petitioner had not attained the ages of 55 or 59-1/2 years
as of Dec. 31, 1998. He was not separated from his employment in
1997 and 1998. He was married during 1997 and 1998; he was
neither separated nor divorced during those years.
4Petitioner also entered zeros on line 60 for total
payments, line 61 for amount overpaid, and line 62a for amount to
be refunded. All remaining lines, except the name, address,
Social Security number, filing status, exemptions, and signature
lines, were left blank.
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