Ramzy M. and Lena Kopty - Page 16




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              Thus, petitioner’s transmittal letter of October 4, 2000,               
         again raises the issue discussed in his letter dated May 27,                 
         2000, quoted above.  That issue involves his contention that the             
         gross distribution reported on the Form 1099-R issued for 1998,              
         consisting of the stock of J.D. Edwards & Co., is overstated, as             
         shown by the fact that the amount reported on the Form 1099-R                
         greatly exceeds the proceeds realized from the sale of the stock.            
         The transmittal letter expresses petitioner’s concern that the               
         amount of the gross distribution reported on the Form 1099-R                 
         would cause additional income of $42,695.14 for 1998.                        
              Petitioners filed their 1999 Federal income tax return on or            
         about November 21, 2001.  That return does not report any of the             
         distributions from petitioner’s IRA at Norwest during 1999 in the            
         aggregate amount of $331,500.  At the same time, the return                  
         reports none of the dividend income in the aggregate amount of               
         $6,093.21 realized by petitioner’s IRA during the year.                      
              Petitioners also filed their 2000 Federal income tax return             
         on or about November 21, 2001.  That return does not report the              
         distributions of $10,000 received from petitioner’s IRA during               
         2000.  Furthermore, that return does not report the dividends of             
         $141.27 realized on the moneys invested in petitioner’s IRA                  
         during 2000.                                                                 
              In the later part of 1999, petitioner consulted doctors at              
         the cardiopulmonary department of the American Hospital in Dubai.            







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