Ramzy M. and Lena Kopty - Page 11




                                        -11-                                          
                        May 13, 1999             30,000                               
                        May 31, 1999             15,000                               
                        July 19, 1999            20,000                               
                        July 19, 1999            50,000                               
                        Sept. 20, 1999           10,000                               
                        Oct. 18, 1999            20,000                               
                        Oct. 18, 1999            10,000                               
                        Oct. 25, 1999            17,000                               
                        Nov. 15, 1999            10,000                               
                        Nov. 29, 1999            10,000                               
                        Dec. 1, 1999             4,500                                
                                                331,500                              
         With one exception, all of the distributions that petitioner                 
         requested from his IRA were accompanied by a Norwest form                    
         entitled “Self-Directed IRA Withdrawal Request”.  According to               
         each such form, the type of withdrawal that petitioner requested             
         was “Premature Distribution (under age 59½) (no known                        
         exception)”.  Each form also instructed Norwest not to withhold              
         Federal income tax from the amount distributed.  The form states:            
                   If I elect not to have Federal income tax                          
              withheld, I am still liable for payment of Federal                      
              income tax on the taxable portion of my distribution; I                 
              also may be subject to tax penalties under the                          
              estimated tax payment rules, if my payments or                          
              estimated tax and withholding, if any, are not                          
              adequate.                                                               
         Finally, as the source of the funds, each form states that “Funds            
         will first be withdrawn from the liquid asset portion of my IRA.”            
              Subsequently, during the year 2000, Norwest Bank Minnesota,             
         NA, sent a Form 1099-R to petitioners reporting gross                        
         distributions of $331,500 from petitioner’s IRA during 1999.                 








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