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withdrawn during 1990 are taxable in that year. With respect to
the balance, petitioner argues that his credit union deposit was
sufficient to meet the requirements of section 402(a)(5). It was
petitioner's understanding that an IRA account had been opened
with the Kansas bank and that he was covered for purposes of the
rollover. Petitioner also believed that the credit union and Mr.
Supinski were connected with petitioner's former employer,
Western, and that they were trying to assist in the rollover
process. Although Mr. Supinski attempted to make it clear to
petitioner that his IRA with the Kansas bank was only for
illiquid assets distributed in kind, petitioner believed that
somehow the credit union, the Kansas bank, and his IRA were
connected.
During the trial, petitioner demonstrated an unfamiliarity
with the role of the Kansas bank, the nature or mechanics of an
IRA account, and Mr. Supinski's role in the entire process.
Petitioner believed that maintaining the plan distributions in
his Western credit union accounts was part of his IRA. Mr.
Supinski was attempting to profit from selling investments to be
included in petitioner's IRA. Petitioner did not make a
distinction between depositing the distribution in the credit
union and the investments recommended by Mr. Supinski for
placement in the IRA.
Petitioner applied for an IRA, which was opened in his name,
albeit in a Kansas bank. Petitioner followed Mr. Supinski's
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