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1993, petitioner began suffering from bilateral tendinitis and
carpal tunnel syndrome. Her carpal tunnel symptoms were minimal,
and surgery was not recommended for either condition. Petitioner
also suffered from periods of depression.
During the years in issue, petitioner was employed by
Cypress Semiconductor Corporation (Cypress) to lay out computer
chips. Petitioner also operated her own startup network
marketing business.
At some point during 2000, Cypress transferred petitioner to
another job because her bilateral tendinitis and carpal tunnel
syndrome were aggravated by her chip-laying duties. Petitioner
was unable to perform her new duties and was transferred back to
her former job. During 2000 or 2001, petitioner’s medical
conditions limited her to working only 4 hours a day.
Petitioner owned several IRAs but became unhappy with the
rate of return from investments held in those accounts. In 1999
and 2000, petitioner received distributions from her IRAs
totaling $57,138 and reinvested the funds in non-IRA
investments.3
Petitioner did not file Federal income tax returns for the
3 During 1999, petitioner received a distribution of $4,992
from her Aim Family of Funds, Aim Balanced Fund B IRA. During
2000, she received the following distributions: (1) $14,518 from
the Aim Constellation Fund A; (2) $14,871 from the Aim Value Fund
B; (3) $6,348 from the Aim Balanced Fund B; and (4) $16,409 from
the Aim Weingarten Fund A.
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