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of the statement on page 15 of Pub. 575 that “[a] lump-sum
distribution must be paid within one tax year” and the
instruction on page 26 that “[t]o qualify [for a rollover], you
must receive your complete share in the plan within one tax year.
* * * You can receive it in more than one part.” The requirement
of section 402(e)(4)(A) is plain; all of the distributions that
constitute a lump-sum distribution must be received within one
taxable year of the recipient, and we are not free to interpret
that requirement as petitioner would have us do. Pub. 575 is
correct in concluding that any rollover must be made within
60 days of the last of such distributions within the taxable
year. Sec. 402(a)(5)(C).
In sum, petitioner's argument is based on the assertion that
he did not receive the balance to the credit payable to him on
account of his separation from service, but that assertion does
not eliminate the requirement under section 402(e)(4)(A) that a
lump-sum distribution be made or paid within one taxable year; at
best, petitioner's assertion undermines the characterization of
the 1992 distribution as a lump-sum distribution. That position,
however, does not advance petitioner's case.
c. Frozen Deposit Rule
Finally, although it is not clear whether petitioner relies
on the special rule for frozen deposits found in section
402(a)(6)(H), that rule is of no benefit to him. That rule,
among other things, tolls the running of the 60-day rollover
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