- 3 -
After concessions by the parties,3 the only issue for
decision is whether the distribution received by petitioner
George Campbell in 1991 from his individual retirement account
with Loyola Federal Savings and Loan is taxable under sections
408(d)(1) and 72.
This case was submitted fully stipulated under Rule 122, and
the facts stipulated are so found. Petitioners resided in Prince
Frederick, Maryland, at the time that their petition was filed
with the Court.
Background
George Campbell (petitioner) was employed by the Maryland
State Highway Administration (the Highway Administration) in 1989
and 1991, and remained so employed at least through the time that
this case was submitted for decision. As an employee of the
Highway Administration, petitioner was a member of the Maryland
State Employees' Retirement System (the Retirement System) until
he transferred to the Maryland State Employees' Pension System
(the Pension System), effective November 1, 1989.
3 Petitioners concede that $7,762.11 and $9,612.14 of the
distributions from petitioner George Campbell's Loyola IRA and
Delaware Charter IRA, respectively, represent earnings and are
includable in petitioners' gross income for 1991.
Respondent concedes that the amount of unreported income
from the IRA distributions is $91,513 (i.e., $172,719 less
$81,206), rather than the greater amount determined in the notice
of deficiency. Respondent also concedes that petitioners are not
liable for the excise tax under sec. 4980A.
See infra p. 9, for further discussion regarding the
parties' concessions.
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