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see also H. Conf. Rept. 105-220, at 380 (1997), 1997-4 C.B. (Vol.
2) 1457, 1850 (wherein the conference committee articulated the
intent to tax conversion income currently such that the “Amounts
that would have been includible in income had the amounts
converted been withdrawn are includible in income ratably over 4
years.”); contrast with sec. 408(d)(3) (a qualified rollover
contribution among nonRoth IRAs is not included in gross income
if it meets certain requirements). Furthermore, the pertinent
parts of the regulations provide:
any taxable conversion amount includible in gross
income for a year as a result of the conversion
(regardless of whether the individual is using a 4-year
spread) is included in income for all purposes. Thus,
for example, it is counted for purposes of determining
the taxable portion of social security payments under
section 86 * * *. [Sec. 1.408A-4, Q&A-9, Income Tax
Regs.]
C. Calculating the Taxable Portion of Petitioners’ Social
Security Benefits
Section 86 provides for the taxability of Social Security
benefits pursuant to a statutory formula. Thus, if a taxpayer’s
“modified adjusted gross income” (MAGI) plus one-half of the
taxpayer’s Social Security benefits exceeds a certain base
amount, then a portion of the taxpayer’s Social Security benefits
is includable in gross income and subject to Federal income tax.
Sec. 86(a) through (d).
Section 86(b)(2) defines MAGI as adjusted gross income, less
certain specified types of income plus tax-exempt interest, which
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