Norma A. Cohen - Page 4

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               On December 23, 1999, Dreyfus issued a check payable to                
          petitioner in the amount of $60,000.  The check was drawn on                
          petitioner’s IRA, and when it was cashed, it was endorsed on the            
          reverse side by petitioner and by Norman.                                   
               As between petitioner and Norman, the evidence is not clear            
          as to who actually received the $60,000.  Apparently, the $60,000           
          was used by petitioner to buy out Norman’s interest in the                  
          marital home where petitioner was then living with petitioner’s             
          and Norman’s two children.                                                  
               A yearend statement of transactions relating to petitioner’s           
          IRA reflected a December 23, 1999, “Premature Distribution” of              
          $60,000.                                                                    
               In early 2000, Dreyfus mailed to petitioner a Form 1099-R,             
          Distributions from * * * IRAs * * *, which reflected the $60,000            
          distributed by Dreyfus from petitioner’s IRA as a taxable                   
          distribution to petitioner.  The Form 1099-R also reflected that            
          Dreyfus had not withheld any Federal income tax from the                    
          distribution.  Petitioner alleges that she never received this              
          Form 1099-R.                                                                
               On April 6, 2000, on her individual Federal income tax                 
          return for 1999, petitioner did not report the $60,000 IRA                  
          distribution as taxable income.                                             
               On February 8, 2002, respondent mailed a notice of                     
          deficiency to petitioner relating to petitioner’s 1999 Federal              






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