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disbelieve petitioner’s testimony that he suffered any loss that
could be carried to 2000. We allow no such loss in the
computation of the deficiency resulting from this proceeding.
3. The Hudson Withdrawal
The parties appear to agree that the Hudson withdrawal, from
a qualified retirement account, would be includable in
petitioner’s gross income unless it was rolled over (i.e., a
matching deposit was made) into another qualified retirement
account within 60 days. See sec. 408(d)(1), (3) (addressing
rollovers of distributions from individual retirement accounts
(IRAs)). The principal dispute between the parties appears to be
over the date the Hudson withdrawal was made. We have found that
it was made on March 1, 2000. We have done so on the basis of
the IRA WITHDRAWAL STATEMENT, which, faintly, in the blocks
marked “Commencement Date” and “Signatures” carries the notation
“3-1-00”, which we take to be the date of withdrawal, March 1,
2000. Because the Hudson withdrawal was redeposited in another
qualified retirement account within 60 days of that date,
petitioner has satisfied the requirements specified in section
408(d)(3) for a tax-free rollover contribution. The Hudson
withdrawal is not includable in gross income.
4. Schedule C Deductions
On the Schedule C, petitioner described his business as
consulting, and he reported expenses for advertising, car and
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