- 8 - mistake and, assuming a mistake was made, whether petitioner took the necessary steps to correct the mistake and transfer the funds to an IRA or other qualified plan.7 In Wood v. Commissioner, 93 T.C. 114 (1989), we discussed the effect of a bookkeeping error committed by a financial institution during the process of rolling over funds into an IRA. In that case, the taxpayer received a distribution of cash and stock from a profit-sharing plan and then established an IRA. The taxpayer was aware that his distribution was required to be rolled over into an IRA within 60 days of receipt. Acting with this knowledge, the taxpayer did everything he could reasonably be expected to do in order to roll over his lump-sum distribution as required by law. For example, the taxpayer met with an IRA trustee, instructed the IRA trustee to open the IRA, and transferred the entire distribution to the IRA trustee for deposit in his IRA. The IRA trustee assured the taxpayer that the taxpayer’s request would be carried out. However, because of a bookkeeping error by the IRA trustee, certain of the trustee’s records indicated that part of the distribution had not been transferred to the IRA within the requisite 60-day period. Approximately 4 months after the 7Respondent states that he did not assert the 10-percent additional tax on amounts received from a qualified retirement plan under sec. 72(t) because petitioner was over the age of 59 1/2 at the time his IRA was closed.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011