Stephen R. Jones - Page 3

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          America (Prudential).  Petitioner was the sole participant in               
          this IRA.  On or about January 29, 1992, petitioner and his then            
          wife, Cynthia Jones (Ms. Jones), commenced divorce proceedings in           
          the Ventura County Superior Court.  As of 1994, petitioner and              
          Ms. Jones were completing their divorce and settling the division           
          of their property.                                                          
               At petitioner’s direction, on May 26, 1994, Prudential                 
          issued a check to petitioner for his full IRA account balance of            
          $68,121.  Petitioner was 47 years old at the time of the                    
               On or before June 12, 1994, petitioner endorsed the                    
          Prudential check over to Ms. Jones.  Ms. Jones did not deposit              
          the IRA distribution check into an IRA or an Individual                     
          Retirement Account.                                                         
               On June 14, 1994, petitioner and Ms. Jones executed a 16-              
          page Stipulation for Judgment and Marital Settlement Agreement              
          (MSA).  The MSA was filed with the Ventura County Superior Court            
          on July 15, 1994.  The MSA had been completed in draft form as              
          early as April 1994.  In relevant part, the MSA provides:                   
                    9.  Property Awarded to Wife.  Husband's interest                 
               in the separate property IRA with Prudential Securities                
               shall be transferred to the respondent CYNTHIA L.                      
               JONES, and thereafter will be her sole and separate                    

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