Joseph P. & Mary A. Dyer - Page 7




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               considered the firm to be the policyholder.  (See                      
               Northwestern’s ltr. of Jan. 19, 2003 when they declared                
               the policy to have lapsed.)  * * *  Northwestern didn’t                
               even have our address or social security number and                    
               apparently called the firm in 2003 to get my wife’s                    
               social security number.  * * *                                         
               On July 10, 2006, respondent issued a notice of deficiency             
          to petitioners for their 2003 tax year.  Under a section in the             
          notice titled “Reasons for the Changes”, respondent stated in               
          pertinent part:                                                             
               These paragraphs explain the items listed in Section 1.                
               Information Reported to IRS.  * * *                                    
               RETIREMENT DISTRIBUTIONS                                               
               We need more information for the distribution shown on                 
               this notice.  We need to know if the income is a                       
               pension or an annuity, an IRA or lump sum rollover, or                 
               an employee savings plan.  If the income is from a                     
               pension/annuity or an Employee Savings Plan and you are                
               recovering your contributions using the General Rule or                
               the Simplified General Rule, please send us a signed                   
               statement with the date of your first pension payment,                 
               the amount you receive monthly, and the total amount                   
               you contribute.  If the income is an IRA or lump sum                   
               and was rolled over, please send us a signed statement                 
               with the amount of the rollover, the date of the                       
               distribution and the date of the rollover.  If the                     
               income is an employee savings plan, please send us a                   
               copy of the document showing the total distribution                    
               amount you received for 2003, and the nontaxable amount                
               of the distribution.                                                   
               In a letter sent to the insurance company dated May 22,                
          2007, respondent requested information relating to the alleged              
          income and stated as follows:                                               










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