- 6 - The third issue is whether a lump-sum payment of $4,822 received by petitioner during 1992 from the employee retirement plan maintained by the convention center is includable in gross income in the year of distribution. The parties stipulated, and petitioner acknowledged at trial, that he received, in November 1992, a lump-sum distribution from the employee retirement plan with the convention center in the amount of $4,822, which he failed to report on his income tax return for 1992. In his petition, petitioner alleged that, since the $4,822 distribution was paid to him in November 1992, the 60-day period in which a rollover of such a distribution is allowed (which is discussed below) continued into January 1993. Therefore, petitioner contends that taxation of the funds, if any, should have occurred in the 1993 tax year rather than 1992. At trial, petitioner acknowledged that the $4,822 distribution was not rolled over into an Individual Retirement Account (IRA) or into any other qualified plan within 60 days, either in 1992 or 1993. Petitioner contended that he could not roll over the distribution for reasons which are not entirely clear to the Court and, to some extent, inconsistent. One reason advanced by petitioner was that he could only contribute $2,000 to an IRA, and, since his distribution exceeded that amount, hePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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