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in income if all requirements are satisfied, sec. 408A(d)(1)(A);
see sec. 1.408A-1, Income Tax Regs.
Beginning in 1998, eligible taxpayers could establish a new
Roth IRA either with a regular contribution or a qualified
rollover contribution (including conversion contributions). See
sec. 408A(c)(3)(B), (c)(6), (d)(3)(C); see also sec. 1.408A-3 and
1.408A-4, Income Tax Regs. Taxpayers could accomplish a
conversion contribution by any of the following three methods:
(1) An amount distributed from a traditional IRA is
contributed (rolled over) to a Roth IRA * * *
(2) An amount in a traditional IRA is transferred in a
trustee-to-trustee transfer from the trustee of the
traditional IRA to the trustee of the Roth IRA; or
(3) An amount in a traditional IRA is transferred to a
Roth IRA maintained by the same trustee. * * *
Sec. 1.408A-4, Q&A-1(a), Income Tax Regs.; see H. Rept. 105-148,
at 339, (1997), 1997-4 C.B. (Vol. 1) 319, 661; S. Rept. 105-33,
at 32, (1997), 1997-4 C.B. (Vol. 2) 1067, 1112.
For tax purposes, the converted amount is treated as a
distribution from the traditional IRA and as a qualified rollover
contribution to the Roth IRA. Sec. 1.408A-4, Q&A-1(c), Income
Tax Regs. Specifically with respect to conversions to a Roth
IRA, the amount distributed from the traditional IRA is treated
as a taxable distribution (except for nondeductible
contributions) and, therefore, included in gross income. See
sec. 408A(d)(3)(A)(i); sec. 1.408A-4, Q&A-7(a), Income Tax Regs.;
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