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to withhold tax of 10 percent, by issuing the following checks to
petitioner:
Date of
A.G. Edwards Normal Tax Gross
Check Distribution Withheld Distribution
July 10, 2001 $1,530 $170 $1,700
August 6, 2001 1,530 170 1,700
August 31, 2001 1,530 170 1,700
September 28, 2001 1,530 170 1,700
November 16, 2001 1,530 170 1,700
December 3, 2001 1,530 170 1,700
Subtotals $9,180 $1,020 $10,200
Total $10,200
The above-described checks issued by A.G. Edwards were endorsed
by petitioner and deposited into petitioner’s Bank of America
checking account.
A.G. Edwards prepared and issued to decedent and petitioner
separate Forms 1099-R (A.G. Edwards Form 1099-R) for 2001 with
respect to the gross distributions of $8,500 and $10,200 that
A.G. Edwards made during that year from decedent’s IRA and
petitioner’s IRA, respectively. The address for decedent and for
petitioner shown in the respective A.G. Edwards Forms 1099-R
issued to them was the same as the address shown in (1) the tax
return that petitioner filed for her taxable year 2001 and
(2) the petition that she filed with the Court. A.G. Edwards
Form 1099-R issued to decedent showed A.G. Edwards as the payer
and decedent as the recipient of a “Gross Distribution” of $8,500
and a “Taxable Amount” of $8,500, which was the total amount of
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