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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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Last modified: March 27, 2008