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contributions to the extent the contributions are considered an
“investment in the contract”. Secs. 72(e), 408(d); Alpern v.
Commissioner, T.C. Memo. 2000-246. Nondeductible contributions
to an IRA minus any prior withdrawals or distributions of
nondeductible contributions constitutes a taxpayer’s investment
in the contract. Sec. 72(e); Campbell v. Commissioner, 108 T.C.
54, 61-62 (1997). Nondeductible contributions, however, must be
designated as such and reported on Form 8606, Nondeductible IRA
Contributions, IRA Basis, and Nontaxable IRA Distributions, in
the manner prescribed by the Internal Revenue Code. Sec.
408(o)(4); Alpern v. Commissioner, supra.
Petitioner admitted that he lacked a complete paper trail
for his IRAs. Petitioner relies on his own testimony to
establish that a portion of the IRA distributions in 2001 was not
taxable.
Petitioner claimed that in 1994 Mellon Bank inappropriately
“converted” an account he held there from a regular account to an
IRA account, and it was these funds that he eventually
transferred to the Strong IRA. We found petitioner’s testimony
to be general, vague, conclusory, and/or questionable in certain
material respects. Petitioner’s testimony was contradictory as
to when he opened this alleged non-IRA account at Mellon Bank
(1980, the late 1980s, or 1993) and as to what kind of alleged
non-IRA account it was (a savings account, a CD, or a “timed
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