Roman G. Satko - Page 3

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               Respondent determined for 1999 a deficiency in petitioner’s            
          Federal income tax of $658.  The issue for decision is whether              
          $2,326.33 of interest distributed to petitioner from the                    
          Prudential Life Insurance Company is taxable as income to                   
          petitioner.                                                                 
                                     Background                                       
               The stipulation of facts and the exhibits received into                
          evidence are incorporated herein by reference.  Petitioner                  
          resided in Warren, Michigan, at the time the petition in this               
          case was filed.                                                             
               In 1985, petitioner purchased a "variable/appreciable                  
          policy" (VAP) from the Prudential Life Insurance Company                    
          (Prudential).  Petitioner believed it was an investment vehicle             
          through which he could fund his retirement.  At the time he                 
          purchased the VAP, petitioner also had an existing life insurance           
          policy with Prudential.  Petitioner agreed to have the premiums             
          for the VAP paid through loans against the cash value of his                
          existing life insurance policy and from investment earnings                 
          derived from the VAP.                                                       
               The VAP premiums, totaling $4,647.83, were paid by loans               
          taken from the cash value of the life insurance policy.  By 1987,           
          the cash value of the life insurance policy had been borrowed in            
          full.  Petitioner was unemployed and unable to pay the premiums             
          on the VAP which caused the policy to lapse.                                






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