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Office of Personnel Management (OPM) as paid to petitioner for
1995 and described by respondent as a “gross distribution” and
(2) $279 of bank account interest listed on Forms 1099-INT,
Interest Income, issued by the “First Union National Bank Of DC”
(the bank) as paid to petitioner for 1995, and respondent’s
allowance of a $2,500 personal exemption and a $3,900 standard
deduction, adjustments which give rise to taxable income of
$22,604. Respondent gives petitioner credit for zero “PRE-PAID
CREDITS (withholding, ES tax payments etc.)”.
OPINION
I. Introduction
A. Petitioner’s Concessions
By the petition, petitioner assigned error to the deficiency
in (and additions to) tax determined by respondent.
Specifically, petitioner claims that respondent erred in
determining that she was taxable on her retirement income. At
trial, she characterized her retirement income (pension) as a
“disability insurance annuity”. Prior to trial, in a letter to
respondent dated November 13, 2002, petitioner’s counsel made the
same argument characterizing petitioner’s pension as “disability
insurance benefits”. On brief, petitioner abandons that argument
as mistaken and concedes that her pension is taxable. We accept
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