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On December 23, 1999, Dreyfus issued a check payable to
petitioner in the amount of $60,000. The check was drawn on
petitioner’s IRA, and when it was cashed, it was endorsed on the
reverse side by petitioner and by Norman.
As between petitioner and Norman, the evidence is not clear
as to who actually received the $60,000. Apparently, the $60,000
was used by petitioner to buy out Norman’s interest in the
marital home where petitioner was then living with petitioner’s
and Norman’s two children.
A yearend statement of transactions relating to petitioner’s
IRA reflected a December 23, 1999, “Premature Distribution” of
$60,000.
In early 2000, Dreyfus mailed to petitioner a Form 1099-R,
Distributions from * * * IRAs * * *, which reflected the $60,000
distributed by Dreyfus from petitioner’s IRA as a taxable
distribution to petitioner. The Form 1099-R also reflected that
Dreyfus had not withheld any Federal income tax from the
distribution. Petitioner alleges that she never received this
Form 1099-R.
On April 6, 2000, on her individual Federal income tax
return for 1999, petitioner did not report the $60,000 IRA
distribution as taxable income.
On February 8, 2002, respondent mailed a notice of
deficiency to petitioner relating to petitioner’s 1999 Federal
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Last modified: May 25, 2011