MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge.
Respondent determined a $1,361 deficiency in petitioner's 2001 Federal income tax. The issues for decision are: (1) What amount of the $2,301 in interest petitioner received from Bank One, N.A. (Bank One), in 2001 is taxable; and (2) what amount of the IRA distributions totaling $9,788 petitioner received from Janus Capital Group (Janus) in 2001 is taxable.
FINDINGS OF FACT
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