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Edwards during 2001 from decedent’s IRA and petitioner’s IRA were
death benefits that are not taxable. Petitioner explained at
trial that she held that belief because some of her friends who
were widows told her during informal discussions that death
benefits are not taxable.13
We turn first to petitioner’s claim at trial that she did
not receive any of the Forms 1099 from Sun Life, A.G. Edwards, or
American General showing the respective distributions that those
companies made during 2001. Petitioner’s claim that she received
none of those forms strains credulity, and we reject it. The
record does not establish, and petitioner does not contend, that
the separate Sun Life Forms 1099-R showing the respective gross
distributions made by Sun Life during 2001 with respect to
decedent’s annuity contracts and the separate A.G. Edwards Forms
1099-R showing the respective gross distributions made by A.G.
Edwards during 2001 from decedent’s IRA and petitioner’s IRA were
addressed to an incorrect address.14 Nor does the record estab-
lish, and petitioner does not contend, that she was having any
problems in receiving mail around the time the payers in question
13Petitioner did not give a similar explanation at trial as
to why she did not include in gross income in the 2001 joint
return the respective distributions of $400 of interest income
and $1,365 of other income made by American General during 2001.
14The record does not contain copies of any Form 1099 that
American General issued with respect to the respective distribu-
tions during 2001 of interest and other income.
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