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Petitioner ceased making payments after he terminated his
employment, and the loan was considered in default. The loan was
repaid in 2000 by an offsetting distribution from Plan 15105 of
$15,552. During October or November of 2000, petitioner made a
direct rollover of $286,390 from Plan 15105 into his Fidelity
Investments IRA Rollover Account (Fidelity IRA). Fidelity
Institutional issued petitioner a Form 1099-R, Distributions From
Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs,
Insurance Contracts, etc., with respect to Plan 15105 for 2000
(the Plan 15105 Form 1099-R). The parties stipulated that the
Plan 15105 Form 1099-R accurately reflected the offsetting
distribution made in satisfaction of the loan and the direct
rollover into the Fidelity IRA, indicated that petitioner made
employee contributions of $1,108, and reported a taxable amount
of $14,443.
Plan 15106 was a qualified retirement plan called the Intel
Corporation Profit Sharing Retirement Plan and was administered
by Fidelity Institutional on behalf of Intel. Petitioner
borrowed money from Plan 15106 and made payments through payroll
withholding. Petitioner ceased making payments after he
terminated his employment, and the loan was considered in
default. The loan was repaid in 2000 by an offsetting
distribution from Plan 15106 of $30,623. On November 6, 2000,
petitioner made a direct rollover of $463,930 from Plan 15106
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Last modified: May 25, 2011