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Date of
A.G. Edwards Normal Tax Gross
Check Distribution Withheld Distribution
February 2, 2001 $1,125 $125 $1,250
February 9, 2001 405 45 450
March 1, 2001 1,530 170 1,700
April 3, 2001 1,530 170 1,700
May 1, 2001 1,530 170 1,700
June 12, 2001 1,530 170 1,700
Subtotals $7,650 $850 $8,500
Total $8,500
The above-described checks issued by A.G. Edwards were deposited
into petitioner’s Bank of America checking account.5
On June 12, 2001, petitioner sent to A.G. Edwards a death
certificate for decedent and a preprinted form prepared by A.G.
Edwards entitled “A.G. Edwards Self-Directed IRA Request Form”
(A.G. Edwards IRA request form). In that form, petitioner
directed A.G. Edwards to make a total distribution rollover of
decedent’s IRA into petitioner’s IRA because of decedent’s death.
In July 2001, petitioner requested A.G. Edwards to make
gross distributions to her from petitioner’s IRA of $1,700 a
month. Pursuant to that request, during 2001, A.G. Edwards made
the following gross distributions totaling $10,200 from peti-
tioner’s IRA, with respect to which an election had been made
5See supra note 3. Decedent endorsed the checks dated Feb.
2 and 9, Mar. 1, and Apr. 3, 2001. The only endorsement on each
of the checks dated May 1 and June 12, 2001, was “FOR DEPOSIT
ONLY”.
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Last modified: May 25, 2011