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Date Check No. Description Amount
7/27/2001 136 Payable to: Discover $2,700.00
8/1/2001 137 Payable to: Citibank 3,450.55
8/21/2001 147 Payable to: First USA 23,000.00
9/5/2001 164 Payable to: Citibank 6,938.63
9/5/2001 165 Payable to: Union Federal27,701.51
9/29/2001 185 Payable to: First USA 1,215.40
10/24/2001 204 Payable to: First USA 1,075.98
Total 66,082.07
Both petitioner’s and Mr. Glenn’s names were on their credit
cards financed through Discover, Citibank, and First USA, and
both of their names were on the home mortgage note they received
from Union Federal. Therefore, petitioner and Mr. Glenn were
jointly liable for the credit card debts and home mortgage which
were paid by the above checks.
From the record, the remaining $57,617.93, which was
deposited into the joint savings and checking accounts, was not
readily traceable. However, on November 28, 2001, the balance in
the joint savings account was $57,878.32.
As stated previously, petitioner and Mr. Glenn reported
pension and annuity income of $165,838 on their joint Federal
income tax return for taxable year 2001. However, they did not
report on their 2001 joint Federal income tax return the 10-
percent additional tax imposed by section 72(t) on early
withdrawals from qualified retirement plans. Accordingly, on
February 25, 2004, respondent issued petitioner and Mr. Glenn a
notice of deficiency for taxable year 2001. In the notice of
deficiency, as previously stated, respondent determined that
petitioner and Mr. Glenn were liable for a tax deficiency of
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