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The issues remaining for decision are:
(1) Is petitioner required to include in his gross income
for the year at issue certain distributions from his retirement
plan (retirement plan distributions) that he received during that
year? We hold that he is.
(2) Is petitioner entitled for the year at issue to a
deduction for a claimed loss with respect to his radiology
practice? We hold that he is not.
(3) Is petitioner liable for the year at issue for the 10-
percent additional tax under section 72 with respect to his
retirement plan distributions that he received during that year?
We hold that he is.
(4) Is petitioner liable for the year at issue for the
accuracy-related penalty under section 6662(a)? We hold that he
is.
FINDINGS OF FACT
Many of the facts have been stipulated and are so found.
At the time he filed the petition in this case, petitioner
resided in Henderson, Nevada.
During 1998, petitioner received from Vanguard Fiduciary
Trust Co. (Vanguard) two retirement plan distributions in the
amounts of $131,555 ($131,555 retirement plan distribution) and
$42,704 ($42,704 retirement plan distribution), respectively.
Vanguard issued to petitioner Form 1099-R, Distributions From
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Last modified: May 25, 2011