Linda Olson - Page 2

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          whether petitioner during 2000 received a $461,709 distribution             
          from an individual retirement account (IRA).  We hold she did.              
                                  FINDINGS OF FACT                                    
               Some facts were stipulated and are so found.  The                      
          stipulations of fact and the accompanying exhibits are                      
          incorporated herein by this reference.  Petitioner resided in               
          Beverly Hills, California, when her petition to this Court was              
          filed.  She filed a 2000 Federal income tax return that did not             
          report any distribution received from an IRA.  Prudential                   
          Securities Inc. (Prudential) reported on a 2000 Form 1099-R,                
          Distributions From Pensions, Annuities, Retirement or Profit-               
          Sharing Plans, IRAs, Insurance Contracts, etc., that petitioner             
          had during 2000 received a taxable distribution of $461,709.19              
          from an IRA.  Respondent in the notice of deficiency determined             
          the same (rounding the $461,709.19 to $461,709).                            
               Petitioner’s brother, Peter D. Olson (Olson), died on                  
          November 14, 1998.  When he died, he owned an IRA held in                   
          Prudential account number 004-R68371-N3 (Olson’s account).  The             
          assets in the IRA at the time of his death included 115,917                 
          shares of the stock of Klever Marketing Inc. (Klever).  Olson, a            
          founder and director of Klever, received those shares on or                 
          before March 4, 1998.  The Klever stock certificate (certificate)           
          underlying those shares, number 6278, stated:                               
               The shares represented by this certificate have not                    
               been registered under the Securities Act of 1933.  The                 





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