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401(a)(9); (2) by amortizing the account balance over a number of
years equal to the life expectancy of the account owner or the
joint life and last survivor expectancy of the account owner and
beneficiary (with life expectancies determined in accordance with
section 1.401(a)(9)-1, Proposed Income Tax Regs., 52 Fed. Reg.
28081 (July 27, 1987)) at an interest rate that does not exceed a
reasonable interest rate on the date payments commence; or (3) by
dividing the account balance by an annuity factor (the present
value of an annuity of $1 per year beginning at the age attained
in the first distribution year and continuing for the life of the
account owner) with such annuity factor derived using a
reasonable mortality table and using an interest rate that does
not exceed a reasonable interest rate on the date payments
commence.
The parties have stipulated that Mr. Jacobsen received
distributions from his individual retirement account of $16,770,
$18,880, $23,330, $33,330, $31,100, and $35,550 in 1992, 1993,
1994, 1995, 1996, and 1997, respectively. At trial, Mr. Jacobsen
presented various computations that he said supported his claim
that the amounts were substantially equal under the annuity
method described in Notice 89-25, supra. Respondent contends
that the amounts distributed were not the amounts calculated for
each year, that petitioners failed to substantiate that the
calculation was based on the correct balance in the retirement
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