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burden of establishing error in respondent’s determinations. See
Lerch v. Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989),
affg. T.C. Memo. 1987-295; Geiger v. Commissioner, 440 F.2d 688,
689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
Accordingly, we sustain respondent’s determination regarding
petitioner’s interest income for 2001.
IRA Distributions
Petitioner stipulated that he received distributions
totaling $9,788 from the Janus IRA in 2001. Petitioner admitted
that the “growth” of his IRA is taxable; however, he contends
that a portion of the IRA distributions is not taxable.
Section 408(d)(1) provides generally that “any amount paid
or distributed out of an individual retirement plan shall be
included in gross income by the payee or distributee, as the case
may be, in the manner provided under section 72.” The term
“individual retirement plan” includes an IRA. Sec. 7701(a)(37).
All distributions during any taxable year are treated as one
distribution, and the value of the contract, the income on the
contract, and the investment in the contract are computed as of
the close of the calendar year in which the taxable year begins.
See sec. 408(d)(2).
Generally, taxpayers have no basis in an IRA. Sec. 1.408-
4(a)(2), Income Tax Regs. A taxpayer has a basis in IRA
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