Richard Bradley - Page 4

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          a section 401(k) account with CIG during both years.  The CIG               
          plan was administered by Merrill Lynch Trust Co., FSB (Merrill              
          Lynch).  In July 2000, petitioner borrowed $9,000 against his               
          section 401(k) account.  Petitioner’s earnings statement for 2000           
          reflects that petitioner repaid $3,420.42 on a section 401(k)               
          plan loan.  The record is unclear as to whether the loan payments           
          were credited to the loan he received in July 2000 or to a loan             
          he received in a prior year, or whether the payments were applied           
          to more than one loan.  Further, to the extent there was a loan             
          in 2001, the terms of the loan and the record of repayments are             
          not made part of the record.                                                
               In 2001, CIG was acquired by Eagle Global Logistics (Eagle).           
          Petitioner was employed by Eagle after the merger and remained an           
          employee with the company for several months in 2001.  Eagle                
          offered a retirement plan to its employees, and petitioner                  
          maintained a retirement account during his employment.  The Eagle           
          retirement plan was administered by ING Life Insurance and                  
          Annuity Co. (ING).                                                          
               In 2001, petitioner received a distribution of $15,322.69              
          from a CIG-sponsored retirement plan.  A Form 1099-R,                       
          Distributions From Pensions, Annuities, Retirement or Profit-               
          Sharing Plans, IRAs, Insurance Contracts, etc., issued to                   
          petitioner by Merrill Lynch reflected the number “1” as the                 







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