- 4 - deposit (regular CDs). Later, some of his CDs were converted into or purchased as individual retirement accounts (IRA CDs). To the extent pertinent to the issues before the Court, petitioner’s retirement planning transactions are described below in greater detail. In 1993, petitioner became a name partner in the law firm of Oldenettel & Sadberry. His partner was Rick Oldenettel. The law firm had a qualified section 401(k) retirement plan in which petitioner participated. The firm accountant was Dan Wendel, from whom petitioner sought informal personal tax and retirement advice from time to time during his tenure with the law firm and thereafter. During 1996, petitioner purchased a number of annuities. In May, he purchased a nonqualified annuity from Glenbrook Life and Annuity with proceeds he received from the settlement of a lawsuit (Glenbrook nonqualified annuity).4 In June, he purchased a second nonqualified annuity from Southern Farm Bureau Life Insurance Co., funded with an initial contribution of petitioner’s regular CDs (SFB nonqualified annuity).5 In 4 Glenbrook Life and Annuity, Flexible Premium Deferred Annuity Contract, policy number GA295240. Petitioner did not elect to include the Glenbrook annuity as a qualified retirement plan under sec. 401(a) or 4974(c)(1), nor did it qualify as an annuity plan under secs. 403(a) and 4974(c)(2). 5 Southern Farm Bureau Life Insurance Co., Flexible (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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