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all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
Sacramento, California.
From 1984 to 2001, petitioner was employed as an attorney
with various section 501(c)(3) organizations, which organizations
made contributions on petitioner’s behalf to four separate
section 403(b) tax-deferred annuity accounts and to one tax-
deferred simplified employee plan/individual retirement account
(SEP-IRA).
The employer contributions made to petitioner’s annuity and
SEP-IRA accounts were made with funds which were not included in
petitioner’s taxable income.
On February 28, 2001, petitioner’s then-current employer
went out of business, and petitioner was laid off. As a result
of being laid off, in the spring of 2001 petitioner applied for
and received unemployment benefits from the State of California.
In June of 2001, petitioner began practicing law as a
partner in her own law partnership, which partnership struggled
financially throughout 2001.
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