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received the property distributed." In other words, if a
taxpayer receives a distribution from a retirement plan and fails
to make a rollover of such distribution to an eligible retirement
plan within 60 days of taxpayer's receipt of such distribution,
the amount shall be taxable under section 72 in the year of
distribution. The term "eligible retirement plan" is defined in
section 402(c)(8)(B) as "(i) an individual retirement account
* * *, (ii) an individual retirement annuity * * *, (iii) a
qualified trust, and (iv) an annuity plan described in section
403(a)." (Emphasis added.)
Petitioner admits receiving a $500 IRA distribution in 1994
but contends that it is not includable in his gross income
because he rolled it over into another IRA account soon after he
received the distribution. When questioned as to how much time
passed between the time petitioner received the $500 and the time
he deposited it into another IRA petitioner testified "I don't
recall". He stated that he was not willing to swear under oath
that he deposited the funds into another IRA on or before the
60th day following the date of their receipt. The parties
stipulated that petitioner phoned Asheville Savings on July 7,
1994, to request a $500 distribution from his IRA. Petitioner
testified that he felt certain he received that $500 distribution
within 2 weeks of the telephone call but he could not testify as
to a specific date. Moreover, petitioner produced the signature
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