- 2 - whether petitioner during 2000 received a $461,709 distribution from an individual retirement account (IRA). We hold she did. FINDINGS OF FACT Some facts were stipulated and are so found. The stipulations of fact and the accompanying exhibits are incorporated herein by this reference. Petitioner resided in Beverly Hills, California, when her petition to this Court was filed. She filed a 2000 Federal income tax return that did not report any distribution received from an IRA. Prudential Securities Inc. (Prudential) reported on a 2000 Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit- Sharing Plans, IRAs, Insurance Contracts, etc., that petitioner had during 2000 received a taxable distribution of $461,709.19 from an IRA. Respondent in the notice of deficiency determined the same (rounding the $461,709.19 to $461,709). Petitioner’s brother, Peter D. Olson (Olson), died on November 14, 1998. When he died, he owned an IRA held in Prudential account number 004-R68371-N3 (Olson’s account). The assets in the IRA at the time of his death included 115,917 shares of the stock of Klever Marketing Inc. (Klever). Olson, a founder and director of Klever, received those shares on or before March 4, 1998. The Klever stock certificate (certificate) underlying those shares, number 6278, stated: The shares represented by this certificate have not been registered under the Securities Act of 1933. ThePage: Previous 1 2 3 4 5 6 7 8 Next
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