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the record before us, we find that respondent has satisfied
respondent’s burden of production under section 7491(c) with
respect to the accuracy-related penalty.
In support of her position that she is not liable for the
accuracy-related penalty under section 6662(a), petitioner
claimed at trial12 that she never received: (1) The separate Sun
Life Forms 1099-R showing the gross distributions made by Sun
Life during 2001 of $25,940 and $170,429 with respect to dece-
dent’s fixed annuity contract and decedent’s fixed/variable
annuity contract, respectively; (2) the separate A.G. Edwards
Forms 1099-R showing the gross distributions made by A.G. Edwards
during 2001 totaling $8,500 and $10,200 from decedent’s IRA and
petitioner’s IRA, respectively; and (3) the separate Forms 1099
showing the distributions made by American General during 2001 of
$400 of interest income and $1,365 of other income, respectively.
In further support of her position that she is not liable
for the accuracy-related penalty under section 6662(a), peti-
tioner claimed at trial that she believed that the respective
gross distributions of $25,940 and $170,429 made by Sun Life
during 2001 with respect to decedent’s annuity contracts and the
respective gross distributions of $8,500 and $10,200 made by A.G.
12At the conclusion of the trial in this case, the Court
directed the parties to file simultaneous opening briefs and
simultaneous answering briefs. However, petitioner filed a
notice of intent not to file posttrial briefs.
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