Diep N. Hoang - Page 2

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          received from Bank One, N.A. (Bank One), in 2001 is taxable; and            
          (2) what amount of the IRA distributions totaling $9,788                    
          petitioner received from Janus Capital Group (Janus) in 2001 is             
          taxable.                                                                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the referenced exhibits are                    
          incorporated herein by this reference.  At the time he filed the            
          petition, petitioner resided in Orlando, Florida.                           
          Interest                                                                    
               Petitioner held three certificates of deposit (CDs) with               
          Bank One that matured in 2001.  During 2001, petitioner received            
          interest payments from Bank One of $568.53, $789.21, and $944.72.           
          IRA Distributions                                                           
               As of May 23, 2000, petitioner had a balance of $9,430.82 in           
          a Strong Funds (Strong) IRA account.                                        
               On August 17, 2000, petitioner established a traditional IRA           
          account with Janus with funds transferred from the Strong IRA               
          account.  Petitioner filled out a “Janus Traditional IRA                    
          Application”, and under the heading “Traditional IRA” he checked            
          the box for “Transfer of existing Traditional IRA from another              
          custodian.”                                                                 
               During 2001, petitioner received IRA distributions from                
          Janus of $19.86, $393.19, $5,410.13, and $3,966.76.  Janus sent             






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