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remaining 12 days of November and $1,322.35 for the month of
December. Thus, through the end of 1998, petitioner’s IRA earned
dividend income in the aggregate amount of $1,832.25 on the net
proceeds realized from the sale of his J.D. Edwards & Co. stock.
In early 1999, the ESOP’s trustee, Wells Fargo Bank, issued
to petitioner a Form 1099-R, Distributions From Pensions,
Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance
Contracts, etc., for tax year 1998. According to that form,
during 1998, petitioner had received gross distributions from the
J.D. Edwards ESOP of $467,817.48 of which the taxable amount is
$42,695.14, and on which Federal income tax of $51.38 had been
withheld. Similarly, Norwest Bank Minnesota, N.A., issued to
petitioner a Form 5498, IRA Contribution Information, on behalf
of Norwest Bank MN NA IRA C/F Ramzy Kopty reporting rollover
contributions of $411,629.63 for 1998. According to that form,
the fair market value of petitioner’s IRA account was
$337,854.33.
During 1999, petitioner’s IRA earned dividend income in the
aggregate amount of $6,093.21. During the year, petitioner
caused Norwest to make distributions from his IRA in the
aggregate amount of $331,500, as follows:
Date Amount
Jan. 4, 1999 $70,000
Jan. 4, 1999 20,000
Feb. 1, 1999 15,000
Apr. 26, 1999 30,000
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