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B. Distributions From Plan 15105 and Plan 15106
Petitioners did not report any distributions made from Plan
15105 or Plan 15106 on their Federal income tax return. However,
petitioners received Forms 1099-R from Fidelity Institutional,
which reflected: (1) An offsetting distribution of $15,552 was
made from Plan 15105 in satisfaction of petitioner’s loan from
Plan 15105; (2) petitioner made employee contributions to Plan
15105 totaling $1,109; (3) due to the employee contributions, the
taxable amount of the offsetting distribution from Plan 15105 was
$14,443; (4) an offsetting distribution of $30,623 was made from
Plan 15106 in satisfaction of petitioner’s loan from Plan 15106;
and (5) petitioner made no employee contributions to Plan 15106.
The parties stipulated the accuracy of the Forms 1099-R, and no
evidence in the record contradicts the Forms 1099-R. This
evidence is sufficient for respondent to meet his burden of
proof. Therefore, we find that $14,443 and $30,623 of the
offsetting distributions from Plan 15105 and Plan 15106,
respectively, are included in petitioners’ gross income.11
C. IRA Rollovers and Distributions
In general, distributions from an IRA are included gross
income in the year received. Sec. 408(d)(1). A distribution to
11 Petitioners did not introduce evidence to contradict the
Forms 1099-R, nor did they address the distributions on brief.
We find that petitioners abandoned any argument that the
offsetting distributions are not included in their gross income.
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