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OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: Respondent determined a
deficiency in petitioners' Federal income tax for the taxable
year 1990 in the amount of $29,434.
The only issue for decision is whether the distribution
received by petitioner Sara B. Childs from her individual
retirement account in 1990 is taxable under sections 408(d)(1)
and 72 or whether such distribution qualifies for relief pursuant
to section 408(d)(4).
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioners resided in Forest Hill, Maryland, at the time
that their petition was filed with the Court.
Petitioner Sara B. Childs (petitioner) was a teacher in the
Baltimore County Public Schools until she retired on November 1,
1989.
Petitioner's Transfer Refund Distribution
As an employee of the Baltimore County Public Schools,
petitioner was originally a member of the Maryland State
Teachers' Retirement System (the Retirement System). However, on
September 29, 1989, petitioner elected to transfer to the
Maryland State Teachers' Pension System (the Pension System).
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