-2-
distributions of cash which petitioner received in 2000 from one
individual retirement account (IRA) and rolled over to another
IRA more than 60 days later are excludable from his 2000 gross
income under the 60-day rule of section 408(d)(3)(A)(i) (60-day
rule) by virtue of the substantial compliance doctrine. We hold
they are not. We also decide whether petitioner is liable for an
accuracy-related penalty under section 6662(a) and (d). We hold
he is.
FINDINGS OF FACT
Some facts were stipulated. The stipulated facts and the
exhibits submitted therewith are incorporated herein by this
reference. We find the stipulated facts accordingly. Petitioner
is an attorney who lived in Pollock Pines, California, when his
petition was filed. He was born on September 5, 1950, and has
been a member of the State Bar of California since 1982. He
presently works as a research lawyer for a superior court in
California.
Petitioner and his companion purchased a home in May 1999.
At the end of 1999, while living in that home, petitioner learned
of a house (house) that was being auctioned in a foreclosure
sale. Petitioner bid on the house during December 1999. His bid
was accepted in or about the second week of January 2000.
1(...continued)
applicable versions of the Internal Revenue Code.
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