George and Elam Campbell - Page 5

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            taxable employer "pick-up contributions",5 and $162,412.78 of                                
            taxable earnings in the form of interest.  The earnings and                                  
            "pick-up contributions", which total $163,106.30, constitute the                             
            taxable portion of the Transfer Refund.                                                      
                  If petitioner had not transferred to the Pension System but                            
            rather had remained a member of the Retirement System, he would                              
            have been entitled to retire at an appropriate age and receive a                             
            normal service retirement benefit, including a regular monthly                               
            annuity.  He would not, however, have been entitled to receive a                             
            Transfer Refund because a Transfer Refund is only payable to                                 
            those who elect to transfer from the Retirement System to the                                
            Pension System.                                                                              
                  As a result of transferring from the Retirement System to                              
            the Pension System, petitioner became, and presently is, a member                            
            of the Pension System.  As a member of the Pension System,                                   
            petitioner will be entitled to receive a retirement benefit based                            
            upon his salary and his creditable years of service, specifically                            
            including those years of creditable service recognized under the                             
            Retirement System.  However, because petitioner received the                                 
            Transfer Refund on account of transferring from the Retirement                               
            System to the Pension System, petitioner's monthly annuity will                              
            be less than the monthly annuity that he would have received if                              



            5           See sec. 414(h)(2).                                                              




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Last modified: May 25, 2011