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petitioner's IRA; i.e., $90,662.11, which consisted of
petitioner's initial deposit and earnings as follows:
IRA deposit: $ 82,900.00
Earnings: 7,762.11
Total distribution: 90,662.11
Distribution of the Delaware Charter IRA
In a letter to Delaware Charter Guarantee and Trust Co.,
dated April 8, 1991, petitioner requested that his IRA be
converted into a non-IRA account prior to April 15, 1991. In
such letter, petitioner stated: "To avoid further IRS penalties I
must have the IRA account closed by April 15, 1991."
Petitioner's IRA was converted into a non-IRA account on June 11,
1991.
The balance of petitioner's Delaware Charter IRA, upon
conversion into a non-IRA account, was $90,818.53, which
consisted of petitioner's initial deposit and earnings as
follows:
IRA deposit: $ 81,206.39
Earnings: 9,612.14
Account balance on conversion: 90,818.53
Petitioners' 1989 Return
On their Federal income tax return for 1989, petitioners did
not include in gross income any of the taxable portion of the
Transfer Refund; i.e., $163,106.30. In 1991, petitioners amended
their 1989 income tax return to include the taxable portion of
the Transfer Refund in gross income. See Dorsey v. Commissioner,
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