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Unless otherwise specified, references to petitioner in the
singular are to petitioner James J. Milner, and all section
references are to the Internal Revenue Code in effect for the
year in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Molalla, Oregon.
Through August of 1998, petitioner was employed as vice
president of lending at Safeway Credit Union (Safeway). In
August of 1998, petitioner was placed by Safeway on
administrative leave. Petitioner received from Safeway a
severance package that included total payments to petitioner of
$21,000 to be made to petitioner over the course of the last 4
months of 1998 with the final payment to be made in January of
1999.
In January of 1999, petitioner’s employment with Safeway was
officially terminated. Shortly thereafter, in order to obtain
funds to continue remodeling petitioners’ home, petitioner
attempted to borrow against his qualified retirement plan (the
plan), which was administered by Safeway. Petitioner however was
unable to obtain a loan from the plan because he was no longer
employed by Safeway.
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Last modified: May 25, 2011