-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:
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Last modified: March 27, 2008