Charlotte and Charles T. Gee - Page 3

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          exhibits are incorporated by this reference, and the facts are so           
          found.  Petitioners resided in Bolivar, Tennessee, when they                
          filed the petition.                                                         
               Petitioner opened an IRA with PaineWebber in 1993.  Her                
          husband at the time, Ray A. Campbell, Jr. (Mr. Campbell), also              
          opened an IRA with PaineWebber in 1993.  Petitioner was married             
          to Mr. Campbell when the IRAs were established and remained                 
          married until Mr. Campbell’s death on June 21, 1998, at age 73.             
               Mr. Campbell was the sole owner of his IRA, account number             
          MN 21719 17, and petitioner was the primary beneficiary.                    
          Petitioner was the sole owner of her IRA, account number MN 21712           
          17, when Mr. Campbell died.                                                 
               Petitioner requested PaineWebber to distribute the entire              
          balance in Mr. Campbell’s IRA to her IRA at PaineWebber.                    
          PaineWebber distributed $1,010,988.38 to petitioner’s separately            
          owned IRA in July 1998 in the form of a direct rollover.                    
          Petitioner was age 51 at the time of the rollover.                          
               Petitioner transferred her IRA funds in November 2000, then            
          totaling $2,646,797.89, to SEI Private Trust Co. (SEI).  In 2002,           
          petitioner requested and received a $977,887.79 distribution from           
          her IRA at SEI.  Petitioner was under age 59� in 2002 when she              
          received the distribution.                                                  
               Petitioners reported the IRA distribution on their joint               
          Federal income tax return for 2002 but did not report or remit              
          the 10-percent additional tax on early distributions.                       
          Petitioners attached a statement to their return stating that SEI           
          had entered the wrong distribution code on the information                  





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