Richard Alan Cronk - Page 4

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          will and testament and, under the terms of that will, bequeathed            
          her entire estate to petitioner.  The will was duly probated,               
          petitioner was recognized as his mother’s sole heir and legatee,            
          and he was placed in possession of her estate.  The record does             
          not indicate what properties, other than the savings bonds,                 
          constituted the mother’s estate.  It appears that the                       
          probate/succession proceedings were concluded in early 2001.                
               Although the record is not entirely clear as to when the               
          following events occurred, it appears that, at some point in                
          2001, petitioner received a notice from the bank where his mother           
          did business, which stated that the annual fee for her safe                 
          deposit box was due.  Petitioner was not aware that his mother              
          had a safe deposit box, and he, accordingly, went through the               
          necessary procedures to have the box opened.  When the box was              
          opened in 2001, petitioner discovered that his mother owned                 
          several series E U.S. savings bonds, which she had purchased over           
          the years.  The bonds totaled $30,000, and petitioner was the               
          named beneficiary on the bonds.  Petitioner then proceeded to               
          redeem the bonds.  Petitioner was paid the principal of the bonds           
          and the interest that had accrued on the bonds.  The interest               
          totaled $31,980.  For the year 2001, petitioner received from the           
          payer bank two Forms 1099-INT, Interest Income, which totaled               
          $31,980 for the interest.  Petitioner did not include the                   
          interest as income on his 2001 Federal income tax return.  The              





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