- 7 -
On December 11, 2000, petitioner transferred 815 shares of
Intel stock from his Fidelity IRA into his US Bancorp IRA. On
December 22, 2000, the Intel stock was sold, and petitioner was
issued a check for $27,000.
US Bancorp issued petitioner a Form 1099-R with respect to
his US Bancorp IRA for 2000. The Form 1099-R reflected the
distributions of $500,000 and $62,930, and the check for $27,000,
for total distributions of $589,930.
D. Petitioners’ 1999 Federal Income Tax Return
Petitioners filed a joint Federal income tax return for 1999
on June 18, 2003.3 Petitioners reported adjusted gross income of
$564,156, itemized deductions of $427,211, a total tax of
$33,735, an overpayment of tax of $116,498. Petitioners
requested a refund of $105,228 and that $11,270 be applied to
their estimated tax for 2000. Petitioners’ 1999 tax return did
not include a Form 6251, Alternative Minimum Tax--Individuals.
Respondent examined petitioners’ 1999 tax year and
determined that petitioners were not entitled to a refund or
estimated tax credit and were liable for alternative minimum tax
of $105,616. On November 17, 2003, respondent assessed
additional tax of $105,616 and interest of $33,935. The
Certificate of Official Record for petitioners’ 1999 tax year
3 Petitioners’ 1999 tax year is not at issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011