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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.
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Last modified: May 25, 2011