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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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