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the back of the house, the foundation, the kitchen, various
windows and doors, a portion of the roof, and the electrical
components under the house. Petitioners estimated the total
expenditures to be approximately $30,000.
About 1985, petitioner began working as a heavy equipment
operator. He suffers from chronic back problems, and in 1988 he
was diagnosed with osteoporosis. Over the years, despite his
back problems, petitioner continued to work as a heavy equipment
operator.
In 2000, petitioner informed his employer that he wanted to
be placed on disability due to the continued problems with his
back. Petitioner’s employer denied his disability request, and
as a result, petitioner resigned from his employment. Petitioner
also applied for, and was denied, Social Security disability
benefits. After being denied disability benefits, petitioner
continued to work as a heavy equipment operator for several
different employers during 2001 and 2002. As of the date of
trial, petitioner continued to hold a special operator’s license
to operate heavy equipment.
During 2000, petitioner received a distribution of $68,444
from his qualified retirement plan (the distribution). As of the
close of 2000, petitioner had not attained the age of 59-1/2.
Federal income tax withholdings of $13,688 were withheld from the
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