- 4 - 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 FederalPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011