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Unless otherwise specified, references to petitioner in the
singular are to petitioner Dennis Burbridge.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Cranford, New Jersey.
Prior to her death on May 27, 1993, petitioner’s mother
maintained with AIG Life Insurance Co. (AIG) a nonqualified
single premium annuity. Petitioner was the beneficiary of the
annuity.
In 1993, after the death of petitioner’s mother, AIG
distributed to petitioner the total $109,737 payable under the
annuity. AIG reflected the total $109,737 distribution on a Form
1099-R, Distributions From Pensions, Annuities, Retirement or
Profit-Sharing Plans, IRAs, Insurance Contracts, etc., which Form
1099-R was mailed by AIG to petitioner and to respondent. On the
Form 1099-R, $44,741 of the total distribution was shown as
taxable income.
As of July 1995, respondent’s records indicated that
petitioner had not yet filed a Federal income tax return for
1993, and on July 5, 1995, respondent prepared for petitioner a
substitute 1993 individual Federal income tax return (substitute
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