-18-
A No. I used -- to clarify, I did not --
I said that I did not prepare this
document at the time that I prepared the
tax return. I'm a budget analyst by
trade. I go to a lot of meetings. I'm
required to analyze things very quickly.
So I did not put this to paper at the
time I prepared my tax return. So to
answer your question, I used what I had
in my SBC balance, I remembered it to be
286-, but I'd already withdrawn 10,000,
so there's a document in here that shows
I had a balance of 276-, so it was one
account and that's what I used to
calculate this amortization schedule.
THE COURT: So –- go ahead, Counsel.
BY MS. GINGRAS:
Q So it does not involve the Orange County
Teachers Federal Credit Union account at
this time?
A Correct.
We find that the record does not identify what retirement
accounts petitioner took into consideration in allegedly
computing the amount of the periodic payments for purposes of
section 72(t)(2)(A)(iv). Furthermore, the record does not show
the balances of those accounts at the time the first distribution
was made. Indeed, petitioner testified that he could not state
the date and amount of any distribution that was a part of the
distribution of $25,000 made during 2001, other than the
distribution of $10,000 made by one of petitioner's SBC accounts
on or about July 18, 2001.
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