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depression would last.
In another letter dated August 11, 1998, Dr. Dillon states
that Mr. Keeley’s depression “impaired his ability to make
decisions, and thus could have affected his ability to get and
hold a job. Depression is known to keep a person from making
clear and forceful decisions.” Petitioners testified that they
thought that Mr. Keeley’s depression was for an indefinite
duration. Mrs. Keeley also testified that, at present, she
observes the continuing effects of Mr. Keeley’s depression such
that “any tasks, job-related or home-related, take him much
longer to complete”.
Also, Mr. Keeley was diagnosed in June 1997 with a herniated
disk and bone spur in his neck, which had been causing him
discomfort for several years. This condition caused weakness and
pain in his left shoulder and arm, which resolved around November
and December 1997. For this condition, Mr. Keeley received
medication, physical therapy, a neurosurgical evaluation, and
magnetic resonance imaging.
Petitioners timely filed joint Forms 1040, U.S. Individual
Income Tax Return, for 1997 and 1998. On both returns, Mr.
Keeley listed his occupation as “sales rep” and Mrs. Keeley
listed her occupation as “secretary”. Petitioners reported as
income their respective IRA and pension distributions received
during the taxable years 1997 and 1998. For each distribution,
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