Albert Lemishow - Page 1

                                   110 T.C. No. 11                                    

                               UNITED STATES TAX COURT                                

                           ALBERT LEMISHOW, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18744-96.               Filed February 18, 1998.            

                    P received distributions from individual                          
               retirements accounts (IRA's) and Keogh accounts                        
               consisting solely of money.  P purchased stock with a                  
               portion of the distributions.  Thereafter, P opened a                  
               new IRA and placed the stock in that IRA within 60 days                
               of receipt of the distributions.                                       
                    Held, secs. 408(d)(3) and 402(c), I.R.C., both                    
               require that a rollover contribution, from a                           
               distribution of money, consist only of money.  Thus,                   
               P's reinvestments of his IRA and Keogh distributions do                
               not constitute rollover contributions and such                         
               distributions are includable in income.  Held, further,                
               the portion of the distributions not invested in the                   
               stock, including the amounts for taxes withheld, are                   
               includable in P's income.                                              

               Albert Lemishow, pro se.                                               

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