Anthony J. and Denise D. Sadberry - Page 4

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          deposit (regular CDs).  Later, some of his CDs were converted               
          into or purchased as individual retirement accounts (IRA CDs).              
          To the extent pertinent to the issues before the Court,                     
          petitioner’s retirement planning transactions are described below           
          in greater detail.                                                          
               In 1993, petitioner became a name partner in the law firm of           
          Oldenettel & Sadberry.  His partner was Rick Oldenettel.  The law           
          firm had a qualified section 401(k) retirement plan in which                
          petitioner participated.  The firm accountant was Dan Wendel,               
          from whom petitioner sought informal personal tax and retirement            
          advice from time to time during his tenure with the law firm and            
          thereafter.                                                                 
               During 1996, petitioner purchased a number of annuities.  In           
          May, he purchased a nonqualified annuity from Glenbrook Life and            
          Annuity with proceeds he received from the settlement of a                  
          lawsuit (Glenbrook nonqualified annuity).4  In June, he purchased           
          a second nonqualified annuity from Southern Farm Bureau Life                
          Insurance Co., funded with an initial contribution of                       
          petitioner’s regular CDs (SFB nonqualified annuity).5   In                  

               4    Glenbrook Life and Annuity, Flexible Premium Deferred             
          Annuity Contract, policy number GA295240.  Petitioner did not               
          elect to include the Glenbrook annuity as a qualified retirement            
          plan under sec. 401(a) or 4974(c)(1), nor did it qualify as an              
          annuity plan under secs. 403(a) and 4974(c)(2).                             
               5    Southern Farm Bureau Life Insurance Co., Flexible                 
                                                             (continued...)           





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