Anne C. Snyder - Page 19

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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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