Bert A. and Julie L. Hedrick - Page 7




                                        - 6 -                                         
         will be entitled to $3,500 of basis in the IRA.  Accordingly,                
         when petitioners receive distributions, they will be entitled to             
         recover $3,500 tax free consistent with applicable law,                      
         essentially on a pro rata basis.  Any income on that investment              
         would continue to accrue in a tax-deferred manner.  See generally            
         sec. 408.                                                                    
              To reflect our disposition of the disputed issue,                       


                                                 Decision will be entered             
                                            for respondent.                           






























Page:  Previous  1  2  3  4  5  6  7

Last modified: November 10, 2007