- 6 -
he had not transferred to the Pension System but had ultimately
retired under the Retirement System.6
Rollover of Petitioner's Transfer Refund
Within 60 days of receiving the Transfer Refund, petitioner
deposited the taxable portion thereof into two individual
retirement accounts (IRA's), as follows:
On December 26, 1989, petitioner deposited $82,900 of the
Transfer Refund into an IRA with Loyola Federal Savings and Loan
(the Loyola IRA).
On January 2, 1990, petitioner deposited $81,206.39 of the
Transfer Refund into an IRA with Delaware Charter Guarantee and
Trust Co. (the Delaware Charter IRA).7
Distribution of the Loyola IRA
On or about April 11, 1991, Loyola Federal Savings and Loan
distributed, and petitioner received, the account balance of
6 It should be recalled that petitioner remained employed
by the State of Maryland at the time that this case was submitted
to the Court.
7 Petitioner deposited a total amount of $164,106.39 into
his two IRA's. However, the taxable portion of petitioner's
Transfer Refund was only $163,106.30. This discrepancy is not
explained in the record.
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