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Petitioners’ legal residence at the time the petition was filed
was Albuquerque, New Mexico.
Dennis W. Farley, Jr. (petitioner) was born December 25,
1942. In January 1994, he retired from United Missouri Bank in
Kansas City, where he had been employed for more than 31 years.3
At the time of his retirement, petitioner was 52 years of age.
Upon retirement, petitioner received lump-sum distributions from
qualified pension and profit-sharing accounts totaling $274,610.
These funds were timely rolled over into self-directed individual
retirement accounts (IRA accounts) pursuant to section 402(c).
During 1995, petitioner commenced receiving periodic
distributions from his IRA accounts.
Petitioner calculated the amount of his periodic
distributions by first calculating an amortized growth rate of
his IRA accounts based on a life expectancy of 30.4 years. After
determining the projected growth of the accounts over this
period, petitioner concluded he could withdraw (or receive
distributions) from his accounts of $80,040 annually. He rounded
3 Paragraph 4 of the stipulation states that petitioner
retired from United Missouri Bank in 1995. However, petitioner
testified that the actual date was Jan. 1994. The Court is not
bound by a stipulation of fact that appears contrary to the facts
disclosed by the record. Rule 91(e); Blohm v. Commissioner, 994
F.2d 1542, 1553 (11th Cir. 1993), affg. T.C. Memo. 1991-636;
Estate of Eddy v. Commissioner, 115 T.C. 135 (2000). The
difference in the dates is not material to the issue in this
case.
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