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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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