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Inc.", or some variation of that name. None of the investors made
their checks payable to the FAC IRA or Mr. Thomson as trustee. All
petitioners, other than Joe O. and Daurine M. Baker, contributed to
the FAC IRA by writing checks drawn on their personal checking
accounts. Petitioners Joe O. and Daurine M. Baker caused the
trustee of their existing IRA's to issue cashier's checks.
After investing in the FAC IRA, all petitioners executed
purchase, lease, maintenance, and buyback agreements with MDA and
executed an IRA adoption agreement with FAC. Mr. Thomson executed
a Form 56 with respect to each petitioner. Mr. Thomson and each
petitioner executed a Form 5305-A.
The rents generated by the bus stop shelter units were
deposited into the El Dorado Bank custodial accounts. The bus stop
shelter units were held in the FAC IRA trust.
None of petitioners reported the distributions from their
IRA's (and in the case of Nurit Haramgaal, she did not report the
distribution from her IRA and pension plan) as a taxable event on
their 1991 Federal income tax returns.
In the respective notices of deficiency to petitioners,
respondent determined that the IRA and pension plan distributions
were taxable events on the predicate that petitioners did not
properly roll over the distributions into qualified IRA's.
Respondent also determined that each petitioner was liable for a
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Last modified: May 25, 2011