- 8 - 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income currently such that the “Amounts that would have been includible in income had the amounts converted been withdrawn are includible in income ratably over 4 years.”); contrast with sec. 408(d)(3) (a qualified rollover contribution among nonRoth IRAs is not included in gross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, whichPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011