- 7 - Petitioner, unaware that she was required to execute various documents in order to accomplish the desired conversion, did not execute these documents prior to August 15, 1990. Thus, the funds in petitioner's First American IRA's were not distributed to and received by petitioner prior to August 15, 1990. First American Bank distributed and petitioner received the account balance of petitioner's IRA's, i.e., $97,227.74, on or about November 6, 1990. Distribution of the Fidelity IRA Petitioners were accustomed to dealing with Fidelity by telephone. On August 14, 1990, petitioner Richard Childs telephoned Fidelity and requested that the account balance in petitioner's Fidelity IRA be transferred into a non-IRA account. Fidelity permitted customers to convert IRA's into non-IRA accounts by instructions given over the telephone. Thus, Fidelity effected the requested conversion, and the account balance in petitioner's Fidelity IRA was constructively withdrawn and received by petitioner on August 14, 1990. Petitioners' 1989 Return On their Federal income tax return (Form 1040) for 1989, filed August 15, 1990, petitioners included the taxable portion of the Transfer Refund in gross income.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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