Bidyut K. Bhattacharyya and Diana T. Bhattacharyya - Page 6

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          into his Fidelity IRA.  Fidelity Institutional issued petitioner            
          a Form 1099-R with respect to Plan 15106 for 2000 (the Plan 15106           
          Form 1099-R).  The parties stipulated that the Plan 15106 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 no employee                    
          contributions, and reported a taxable amount of $30,623.                    
          C.   Petitioner’s Individual Retirement Accounts (IRAs)                     
               As described above, petitioner made direct rollovers from              
          Plan 15105 and Plan 15106 to his Fidelity IRA totaling $750,320             
          in 2000.  Petitioner received the following distributions from              
          his Fidelity IRA:                                                           

                       Date                    Amount                                 
                       Nov. 2, 2000        $100,000                                   
                       Nov. 9, 2000        10,000                                     
                       Nov. 9, 2000        20,000                                     
                       Nov. 16, 2000       30,000                                     
                       Total               160,000                                    
               On November 9 and 16, 2000, petitioner made direct rollovers           
          of $500,000 and $62,930, respectively, from his Fidelity IRA into           
          another IRA administered by US Bancorp Piper Jaffray (US Bancorp            
          IRA).  On November 10 and 17, 2000, petitioner received                     
          distributions of $500,000 and $62,930, respectively, from his US            
          Bancorp IRA.                                                                






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