- 5 - the distribution within 60 days. Neither the Code nor the regulations provide relief from taxation of the amount distributed to petitioner from an IRA but not timely rolled over. See Wood v. Commissioner, 93 T.C. 114, 119 (1989). Although we are sympathetic to petitioner’s plight, we hold that the IRA distribution to petitioner in 1996 is includable in his 1996 income. Accordingly, petitioner’s claim for overpayment is denied. In reaching all of our holdings herein, we have considered all arguments made by the parties, and to the extent not mentioned above, we find them to be irrelevant or without merit. To reflect the foregoing, Decision will be entered finding no deficiency or overpayment.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011