Timothy W. and Suzanne M. Coffield - Page 3

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          (WEC) until 1991.  In July 1991, petitioner ceased employment at            
          WEC, moved to Georgia, and began working for Westinghouse                   
          Savannah River Co. (WSR).                                                   
               Petitioners purchased a home in Evans, Georgia, on September           
          30, 1991, for $219,900.  They sold their home in Pittsburgh on              
          October 15, 1991, for $112,000.  To finance a portion of the                
          purchase price of the new home, petitioner withdrew a total of              
          $51,002 from his WEC savings program, a qualified retirement                
          plan, by two requests dated July 12, 1991.  The withdrawals                 
          constituted only a portion of the savings plan.  As of June 30,             
          1991, petitioner's Statement of Accounts from the savings plan              
          shows that he had a total of $24,153.63 in "after-tax                       
          contributions".  We assume that between June 30th and the date of           
          distribution, petitioner made some additional after-tax                     
          contributions.  At the time of the withdrawal petitioner had                
          contributed approximately $25,000 to the savings plan all of                
          which was withdrawn.  A statement for December 31, 1991, shows no           
          after-tax contributions remaining in petitioner's account.  WEC             
          issued a Form 1099-R for 1991 reporting $25,709 of the gross                
          distribution as taxable income to petitioner.  Petitioners                  
          apparently did not receive the Form 1099-R until after they filed           
          their Federal income tax return for 1991.                                   
               Petitioners did not report any income as a result of the               
          distribution on their 1991 joint Federal income tax return.  In             





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