Anne C. Snyder - Page 10

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          tive gross distributions.  The address for petitioner shown in              
          each such form was the same as the address shown in (1) the tax             
          return that petitioner filed for her taxable year 2001 and                  
          (2) the petition that she filed with the Court.  One Sun Life               
          Form 1099-R showed a “Gross Distribution” of $25,940.28 and a               
          “Taxable Amount” of $25,940.28, which was the amount of the                 
          distribution that Sun Life paid to petitioner in 2001 with                  
          respect to decedent’s fixed annuity contract.  The other Sun Life           
          Form 1099-R showed a “Gross Distribution” of $170,429.52 and a              
          “Taxable Amount” of $170,429.52, which was the amount of the                
          distribution that Sun Life paid to petitioner in 2001 with                  
          respect to decedent’s fixed/variable annuity contract.  The                 
          “Distribution Code(s)” shown in each Sun Life Form 1099-R was               
          “4", and the box entitled “IRA/SEP/SIMPLE” was checked.4                    
               During 2001, petitioner received interest of $400 and other            
          income of $1,365 from American General Life Insurance Company               
          (American General).                                                         
               During 2001, A.G. Edwards made the following gross distribu-           
          tions totaling $8,500 from decedent’s IRA, with respect to which            
          an election had been made to withhold tax of 10 percent, by                 
          issuing the following checks to decedent:                                   


               4The instructions to Form 1099-R for 2001 describe distribu-           
          tion code “4" as “Death.”  Those instructions also state:  “If              
          the IRA/SEP/SIMPLE box is checked, you have received a tradi-               
          tional IRA, SEP, or SIMPLE distribution.”                                   




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