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that respondent has satisfied respondent’s burden of production
with respect to that penalty.
We turn first to the two retirement plan distributions that
petitioner received during 1998 and that he did not report as
income for that year. It is petitioner’s position that he was
not required to report those distributions as income for the year
at issue because he timely transferred, or rolled over, those
distributions into an eligible retirement plan.4 In support of
his position, petitioner relies on his testimony and two exhib-
its. We are unwilling to accept that evidence as establishing
petitioner’s position regarding his retirement plan distribu-
tions. Petitioner’s testimony was general, conclusory, vague,
and uncorroborated. In this connection, petitioner could not
even recall what happened to the $132,092.20 that he withdrew
from petitioner’s American Savings Bank CD on April 6, 1998. As
for the two exhibits on which petitioner relies, those exhibits
show only that on March 3, 1998, petitioner purchased from the
Bank a certificate of deposit in the amount of $131,555 and that
on April 6, 1998, he withdrew that amount, as well as interest
credited thereto. The record contains no evidence as to what
4Although not altogether clear, petitioner may be arguing
that he rolled over only the $131,555 retirement plan distribu-
tion and not the $42,704 retirement plan distribution. Because
the record is not altogether clear on this point, we shall
proceed on the assumption that both of those distributions are at
issue in this case.
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