William Lenihan - Page 6

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               Petitioner reported those items on the Nov. 10 return, and,            
          in addition, (1) on the attached Schedule C, Profit or Loss From            
          Business, he reported $7,848 of gross income from a business                
          described as “consulting”, (2) on the attached Schedule D,                  
          Capital Gains and Losses, he reported $4,939 of proceeds from               
          sales of capital assets, and (3) on the attached Schedule E,                
          Supplemental Income and Loss, he reported rents and royalties               
          totaling $43,653.                                                           
          The Hudson Withdrawal                                                       
               On March 1, 2000, petitioner withdrew $29,996 from Hudson              
          United Bank (the Hudson withdrawal).  The statement evidencing              
          the Hudson withdrawal is entitled “IRA WITHDRAWAL STATEMENT”,               
          identifies an IRA account in petitioner’s name, and describes the           
          account as a “Traditional IRA”.  During March and April 2000,               
          petitioner deposited $29,996 into a Dreyfus Trust Co. account in            
          his name, described on a transcript of that account as an account           
          “UNDER IRA PLAN”.                                                           
          Schedule A Items                                                            
               Petitioner did not claim a standard deduction on the Nov. 10           
          return, but, rather, he deducted the sum of the amounts that he             
          had itemized on a Schedule A, Itemized Deductions, thereto.  On             
          the Schedule A, petitioner itemized amounts for medical and                 
          dental expenses, State and local income taxes, real estate taxes,           
          personal property taxes, investment interest, cash charitable               






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