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the distributions of the five surrendered life insurance
policies.
On April 25, 2001, Northwestern sent petitioner a letter
which generally explained the calculation of the taxable portion
of petitioners’ surrendered life insurance policies.
Northwestern also provided petitioner a Surrender of Policy
Statement which detailed the policy value and the net proceeds
with respect to each surrendered life insurance policy.
On June 29, 2001, Northwestern sent a letter to petitioner
which further explained the calculation of the taxable portion of
the surrendered life insurance policies.
On October 2, 2002, in a sworn affidavit, Linda A. Schaefer
(Ms. Schaefer), Northwestern’s Director of the Policyowners
Department, set forth the total policy cash value, the net cost,
and the net taxable gain with respect to each of petitioners’
five surrendered life insurance policies. Ms. Schaefer’s
statement also explained in detail how each of these amounts was
computed. In a second sworn affidavit bearing the same date, Ms.
Schaefer provided a detailed history of the premiums paid and the
loans made with respect to petitioners’ surrendered life
insurance policies.
Petitioner testified that he received annual statements from
Northwestern with respect to the surrendered life insurance
policies which detailed premium and loan payments. Petitioner
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