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petitioner Forms 1099-R, Distributions From Pensions, Annuities,
Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts,
etc., for these distributions. The Forms 1099-R listed the
taxable amounts of these distributions as $19.86, $393.19,
$5,410.13, and $3,966.76.
During 2001, petitioner also held a non-IRA account with
Janus.
2001 Tax Return
On his 2001 Federal income tax return, petitioner reported
$92.45 in interest, $7,325 of ordinary dividends, zero of total
IRA distributions, and zero of taxable IRA distributions. The
reported interest was from First Union and Huntington National
Bank. The reported ordinary dividends were from Invesco,
Fidelity, American Century, Janus, Vanguard, and PBHG.
Notice of Deficiency
In a notice of deficiency, respondent determined that
petitioner failed to report $2,301 in interest and a $9,788
taxable IRA distribution.2
2 Respondent did not seek to increase the deficiency by the
amounts of the interest ($1.46) and the IRA distribution ($1.94)
in excess of the amounts determined in the notice of deficiency.
Respondent rounded the figures reported to the Internal Revenue
Service down to whole dollars in his computations.
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Last modified: May 25, 2011