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on the above Schedules C for 1999 and 2000 reflect Mr. Kopty’s
travel between his home in Belgium and his business in the United
Arab Emirates.
On or about July 1, 1998, after leaving the employ of J.D.
Edwards & Co., petitioner sent a distribution request form to the
company asking the company to distribute to him the shares of
stock and cash held in his ESOP account. As completed by
petitioner, the distribution request form states: “I elect a
payout of all my whole shares of J.D. Edwards stock, plus cash, *
* * payable to me with the applicable taxes withheld for federal
tax.”
On the following day, petitioner transmitted a facsimile of
the distribution request form to a representative of Norwest
Investment Services, Inc. (hereinafter Norwest). Several days
later, on or about July 8, 1998, petitioner applied to open a
self-directed IRA with Norwest. As completed by petitioner, the
application states that petitioner wanted to establish a
“Rollover IRA”.
On or about July 15, 1998, in response to petitioner’s
distribution request, the ESOP’s trustee, Wells Fargo Bank, sent
10,323 shares of J.D. Edwards & Co. stock to the transfer agent
and registrar of the stock, Harris Trust Co. of California, with
instructions to reissue the stock in petitioner’s name. In
accordance with those instructions, on or about July 30, 1998,
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