- 5 - proceeds in U.S. Treasury securities. He did not roll over the proceeds into an Individual Retirement Account (IRA). Petitioner and Mr. Mitchell received two Forms 1099-R from the State of Maryland indicating that the taxable portion of the transfer refund distribution was $629,083.14. Petitioner was aware of the timing and amount of the transfer refund distribution and knew that Mr. Mitchell had purchased Treasury securities with the proceeds. In January 1992, and for approximately 5 months thereafter, petitioner was suffering from shingles, the severity of which caused her to be bedridden at various times and absent from work for extended periods. In March of 1992, Mr. Mitchell died suddenly as the result of a pulmonary embolism. Sometime shortly after April 15, 1992, petitioner contacted Mr. Emerson Browne, the family’s longtime tax adviser, concerning the preparation of a 1991 Federal income tax return. She provided Mr. Browne with the records she could find, including the Forms 1099-R issued by the State of Maryland with respect to the transfer refund distribution. She did not find, and therefore did not provide to Mr. Browne, the letter from the Maryland State Retirement and Pension Systems that had advised Mr. Mitchell that the transfer refund was potentially subject to taxation whether rolled over or not.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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