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contributions as "IRA CONTRIBS:". In 1992, petitioner's employer
paid $1,920 into the Guardian account.
The Guardian account in 1992 made three payments to
petitioner, $750, $915.11 and $759.25, totaling $2,424.36. The
1992 account summary for the Guardian account describes a
premature distribution of $2,424.36, of which $12.67 was Form
1099 dividends. The 1992 account summary lists "Form 5498" ("IRA
Contribution Information") total contributions of $1,920, and a
remaining account value of $155.
Petitioner was not yet 59 1/2 at the time he received the
retirement account distributions from Guardian and from a second
account with Prudential Insurance Company of America
(Prudential). In 1992, the Prudential account paid to petitioner
a $268 retirement account distribution.
Petitioners reported on their 1992 Federal income tax return
as IRA distributions includable in income the retirement
distribution to petitioner from Guardian. Petitioners did not
deduct any amount as an IRA deduction. Petitioners did not
report the retirement distribution from Prudential or compute the
10 percent tax on premature distributions from either account.
Respondent examined petitioners' return and made adjustments
including a determination that the Prudential distribution is
includable in gross income and that retirement distributions to
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Last modified: May 25, 2011