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in a retirement plan is taxed one-half to each spouse except
where Congress has specified otherwise; e.g., in sections
219(f)(2), 402(e)(4)(G), and 408(g). In Karem v. Commissioner,
100 T.C. 521, 529 (1993), we held that a pension distribution
subject to section 402(e)(4)(G) was taxable entirely to the
participant even though his former spouse was considered a one-
half owner under State community property law. Unlike the
taxpayer in Powell, the taxpayer in Karem had elected the multi-
year averaging method then available under former section 402(e)
for computing the tax due on lump-sum distributions. As a
result, the distributions were subject to former section
402(e)(4)(G), which provided that “the provisions of this
subsection * * * shall be applied without regard to community
property laws.” Consistent with these opinions, we hold that
section 402(g) precludes taxation of petitioner’s former spouse
as a distributee in recognition of her State community property
interest in petitioner’s IRA’s. Accordingly, the distributions
from petitioner’s IRA’s are wholly taxable to petitioner.
B. Nonrecognition Under Section 408(d)(6)
Petitioner alternatively contends that the distribution and
transfer of his IRA proceeds pursuant to the dissolution judgment
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