-16- included in petitioner's "SBC Savings Plan", the Employee Deferred Tax Account, the Company Contributions Account, and the Rollover Account. According to that statement, the grand total of those accounts amounted to $276,205.59 after a withdrawal of $10,000 from the rollover account. On the basis of that single statement, petitioner contends that the balance of his SBC account was $286,205.59 as of July 16, 2001, the date of the $10,000 distribution. Similarly, the record contains page 1 of only one statement from petitioner's account with OCTFCU. The other pages of the statement were not introduced into evidence. On the basis of that partial statement, petitioners contend that the balance in petitioner's OCTFCU IRA was $51,118.05 on December 1, 2001. In a memorandum dated November 7, 2006, to respondent's attorney, petitioner attempts to explain how he had arrived at "$286,000", the account balance he used in his calculation of substantially equal periodic payments. Petitioner's memorandum states: "I cannot recreate exactly $286,000.00 but I will get very close." Petitioner's memorandum refers to the statement of his SBC account and the statement of his OCTFCU account which are described above. Petitioner's memorandum then states as follows:Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: March 27, 2008