Laura D. Seidel - Page 12

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               Petitioner admitted that she “didn’t know anything about               
          antique and estate jewelry as to value before [she] started the             
          business.”  During taxable year 1999, petitioner purchased a                
          considerable number of books and periodicals to assist her in               
          learning the business of selling and repairing antique and estate           
          jewelry.                                                                    
          Additional Tax--Section 72(t)                                               
               During taxable year 1999, petitioner received a taxable                
          distribution from her 401(k) plan held by Putnam Investments of             
          $10,412.  Petitioner was “nearing [her] 40th birthday” in 1999.             
          Audit Examination                                                           
               Petitioner timely filed a Form 1040 for taxable year 1999.             
          Petitioner attached to her Form 1040 for taxable year 1999 a                
          “Special Handling” cover letter requesting a review of her                  
          return.  Respondent mailed petitioner a letter dated June 9,                
          2000, thanking her for her inquiry and stating that the IRS had             
          not “resolved the matter.”  Petitioner received a letter dated              
          September 14, 2001, advising her that based upon review of third            
          party records, respondent proposed changes to her Form 1040 for             
          taxable year 1999.  Petitioner never entered into a closing                 
          agreement with the IRS with respect to taxable year 1999.                   
          Petitioner never received a letter stating that the IRS had                 
          accepted her 1999 tax return, nor had she received a letter                 
          stating that her 1999 tax return had been audited as requested.             






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