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section 6673. Unless otherwise indicated, all section references
are to the Internal Revenue Code in effect for the years in
issue.
Background
All of the facts have been stipulated, and the stipulated
facts are incorporated as our findings by this reference.
Petitioner resided in New York at the time that he filed his
petition.
During 1999 and 2000, Frontier Telephone of Rochester paid
petitioner compensation of $90,319 and $91,192, respectively.
HSBC Bank, USA, paid petitioner $34 of interest income in each
year. Level County Bank of Boston paid petitioner $17 of
dividends in 1999, and Equiserve paid petitioner $18 of dividends
in 2000.
During 1999, Level County Bank of Boston paid petitioner
$2,970 of gross proceeds from the sale of stocks and bonds.
Petitioner has offered no proof of any basis in the stocks and
bonds sold.
During 2000, Equiserve paid petitioner $1,942 of gross
proceeds from the sale of stocks and bonds. Petitioner has
offered no proof of any basis in the stocks and bonds sold.
During 2000, Western Regional OTB Corp. paid petitioner
$3,009 of gross proceeds from gambling. Petitioner has offered
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