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validity of the divorce judgment and contends that he is still
married to Phyllis Alpern.
On April 8, 1993, petitioner filed a voluntary petition in
bankruptcy under chapter 7 of the U.S. Bankruptcy Code in the
U.S. Bankruptcy Court for the Northern District of Illinois,
Eastern Division (bankruptcy court), case No. 93-B-07643. The
bankruptcy court entered an order discharging the debtor in this
case on September 28, 1993. By order dated October 12, 1993, the
bankruptcy court granted petitioner’s motion to convert the case
to a chapter 11 proceeding under the Bankruptcy Code. An order
of Discharge of Debtor under the chapter 11 proceeding was
entered on July 18, 1994, by the bankruptcy court.
In 1996, petitioner received IRA distributions of $12,905.89
from Fidelity Service Co. (Fidelity).3 Though petitioner
reported total IRA distributions of $12,905.89 on line 15a of his
1996 Federal income tax return, he reported only $6,000 as the
taxable amount of his IRA distributions for 1996 on line 15b of
his return. In addition, petitioner did not attach a Form 8606,
Nondeductible IRAs (Contributions, Distributions, and Basis), to
2(...continued)
had previously entered in the case on May 29, 1992.
3 Fidelity reported two separate IRA distributions for
the 1996 taxable year to the Internal Revenue Service on Forms
1099-R, Statements for Recipients of Distributions From Pensions,
Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance
Contracts, etc., in the amounts of $1,205 and $11,700.
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