Charlotte Marie Scott - Page 5

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          covered only herself.  However, in 2000, petitioner extended her            
          COBRA coverage to include her husband, which resulted in her                
          premiums increasing to $772 per month.  Petitioner was notified             
          in 2001 that such coverage was canceled retroactively to November           
          2000 due to unpaid premiums.  Petitioner would eventually file              
          for bankruptcy in 2001.                                                     
               During 2000, the year in issue, petitioner withdrew                    
          $1,168.39 from her Vanguard 401(k) qualified retirement plan and            
          $10,000 from her Gruntal IRA.  Petitioner did not roll over the             
          distributed amounts into another qualified employee retirement              
          plan or individual retirement plan.  Petitioner reported the                
          $11,168.39 combined amount withdrawn on her 2000 Federal income             
          tax return.  Although the amount of the distributions was                   
          reported on the return, petitioner did not compute the 10-percent           
          additional tax due for the early withdrawals.  Petitioner, who              
          was born in 1948, was 52 years of age in 2000 when the                      
          distributions were made.                                                    
               Petitioner filed a joint Federal income tax return with her            
          then-husband, Robert J. Scott, for the taxable year 2000.                   
          Between January and July 2000, Mr. Scott was a salesman with the            
          Pittsburgh Post Gazette.  In July, he moved to San Francisco,               
          California, to live with petitioner and began work with the San             
          Francisco Chronicle, where he remained employed until November              
          when he left for Florida.                                                   

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