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custodial account at the El Dorado Bank in Newport Beach,
California, to collect the rental income generated from the lease
agreements entered into with MDA.
Mr. Thomson executed a Form 56 (Notice Concerning Fiduciary
Relationship) with respect to each investor in the FAC IRA. Both
Mr. Thomson and each investor in the FAC IRA executed a Form 5305-A
(Individual Retirement Custodial Account) assigning the IRA
contributions to the custodial account.
Petitioners' Investments in the FAC IRA
All petitioners in this case caused distributions to be made
out of existing qualified IRA's (and in one instance an existing
qualified IRA and a pension plan4) for the purpose of rolling over
the distribution into the FAC IRA. The distributions and
contributions into the FAC IRA were as follows:
Distribution
from IRA/ Contribution
Petitioner Pension Plan Date to FAC IRA Date
Gordon J. Schoof $62,151.00 1 0 2/05/91$65,000.00 02/07/91
3,579.77 02/07/91
Bonnie L. Schoof 7,397.69 08/16/91 20,000.00 09/04/91
10,709.06 08/26/91
Lyman K. Kennedy 5,000.00 04/18/91 5,000.00 04/24/91
Judith Kennedy 5,000.00 04/18/91 5,000.00 04/24/91
4 Only petitioner Nurit Haramgaal caused a distribution
to be made from a pension plan.
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