Robert A. Hall and Laverne M. Hall - Page 17

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          1Total nondeductible contributions means all contributions prior            
          to the distribution date minus amounts received before such date to         
          the extent excludible from gross income.  Sec. 72(e)(6).                    

               The remainder of petitioner's distribution after                       
          determination of the nontaxable amount represents the payment to            
          him of income and as the parties have agreed is subject to the              
          10-percent premature distribution tax under section 72(t).  We              
          direct that these computations be made by the parties and                   
          submitted under Rule 155.                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               


























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Last modified: May 25, 2011