Michael J. Kulzer & Jan K. Bielman-Kulzer - Page 14




                                        -13-                                          
          The following distributions were made from petitioner's                     
          retirement accounts:                                                        
               Year     SBC 1, 2, 3    SBC 401K      OCTFCU     Other                 
               2001      $32,000     $44,180      $12,118        ---                  
               2002    ---  ---    25,000 ---                                         
               2003    ---  ---    36,439 ---                                         
               2004    ---  --- ---    $70,000                                        
               2005         ---  --- ---     17,000                                   
          Of the above distributions, petitioners claim that the following            
          amounts are part of the series of substantially equal annual                
          payments that began in 2001:                                                
               Year     SBC 1, 2, 3    SBC 401K      OCTFCU     Other                 
               2001  $25,000   ---      ---      ---                                  
               2002    ---   ---   $25,000 ---                                        
               2003    ---   ---    12,000      ---                                   
               2004    ---   --- ---    $12,000                                       
               2005    ---   --- ---     12,000                                       
               As shown above, the distributions that petitioners claim to            
          be part of the series of substantially equal periodic payments              
          were made in different amounts.  The amount of the annual payment           
          for 2001 and 2002 is $25,000, whereas the amount of each of the             
          annual payments allegedly made after 2002 is $12,000.                       
               Furthermore, the distributions that petitioners claim to be            
          part of the series of substantially equal periodic payments were            
          made from different accounts.  The account from which the alleged           
          periodic payment was distributed in 2002, i.e., OCTFCU, is                  
          different from the account from which the payment was distributed           








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