Samuel A. Cole - Page 2

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               (2) whether petitioner is entitled to deduct additional                
          expenses in 2001;                                                           
               (3) whether petitioner is liable for the 10-percent                    
          additional tax on his Individual Retirement Account (IRA)                   
          distribution under section 72(t)(1); and                                    
               (4) whether petitioner received $17 of interest from the               
          Commonwealth of Virginia in 2001.                                           
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Knoxville, Tennessee, at the time that he             
          filed his petition.                                                         
               Petitioner was employed as a computer software consultant              
          by Metamor Enterprise Solutions, Inc. (Metamor), until his                  
          position was eliminated and he was discharged on March 30, 2001.            
          While working for Metamor, petitioner traveled from his home to             
          temporary client sites to make sales presentations to businesses            
          regarding computer software, prepare proposals for implementation           
          of the software for the business, and, if it was purchased,                 
          implement the computer software.  At times, petitioner’s job with           






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