- 9 - are not present here. For an individual taxpayer, AGI is gross income minus a specifically enumerated list of deductions, which deductions also are not present here. Sec. 62. Finally, section 61 defines gross income as “all income from whatever source derived”, unless otherwise provided. Section 61(a)(9) and (11) expressly defines gross income to include income from annuities and pensions. Therefore, petitioners’ gross income includes their conversion income. See sec. 408A(d)(3)(A), (C). Accordingly, petitioners had MAGI of $43,127.58 in 1998 and $48,742.89 in 1999, sec. 86(b)(2), and they received Social Security benefits of $8,838 and $15,882, respectively. As a result, petitioners’ MAGI plus one-half of their benefits ($47,546.58 for 1998 and $56,683.89 for 1999) exceeds the base amount, and, therefore, a portion of their Social Security benefits is taxable. See sec. 86(a)(2), (c)(2). D. The Tax Consequences of Petitioners’ IRA Conversion Petitioners agree that their conversion income is a “taxable rollover” requiring them to pay income tax on such income. However, petitioners object to the conversion income’s being characterized as a “taxable distribution” that has the effect of making their Social Security benefits taxable under section 86. Petitioners, however, do not fully appreciate the tax consequences involving a conversion of a traditional IRA to a Roth IRA.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011