Robert A. Hall and Laverne M. Hall - Page 17
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1Total nondeductible contributions means all contributions prior
to the distribution date minus amounts received before such date to
the extent excludible from gross income. Sec. 72(e)(6).
The remainder of petitioner's distribution after
determination of the nontaxable amount represents the payment to
him of income and as the parties have agreed is subject to the
10-percent premature distribution tax under section 72(t). We
direct that these computations be made by the parties and
submitted under Rule 155.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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