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Principal and accrued interest were payable upon the transfer of
the property or death of Ms. Moore, whichever came first. In
1998, Ms. Moore died. Petitioner, on her 1999 Federal income tax
return, reported a $25,000 loss.
From 1992 to 2000, petitioner was employed by the City of
Seattle (the City) as a license and standards inspector. During
this period she had a digestive disorder. Although petitioner
could not eat during work hours, her digestive disorder imposed
no other physical limitations on her ability to work. In 1999,
petitioner requested to have her schedule modified from a 10 1/2-
hour workday (i.e., with a 1/2-hour lunch break) to a 10-hour
workday without a lunch break. The City denied petitioner’s
request. In response, on August 1, 2000, petitioner resigned.
After petitioner resigned, the City granted her request, but she
did not accept their accommodation.
In 2000, petitioner received a $46,996 Individual Retirement
Account (IRA) distribution. Petitioner reported the distribution
on her 2000 Federal income tax return and paid income tax
relating to the gross amount but did not pay the 10-percent
additional tax pursuant to section 72(t)(1).
By notice of deficiency dated December 31, 2002, respondent
determined deficiencies of $4,382 and $4,700 relating to 1999 and
2000, respectively. On April 4, 2003, petitioner, while residing
in Memphis, Tennessee, filed her petition with this Court.
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Last modified: May 25, 2011