-25- Furthermore, in this case, the 60-day period is satisfied regardless of the date used as the date of the "transfer of a distribution". See sec. 402(c)(3). That date could be August 4, 1998, the day on which petitioner hand-delivered the certificate to Norwest, or August 24, 1998, the day on which Norwest recorded the transfer on its statement for petitioner’s IRA for the period ending August 31, 1998. Petitioners do not deny that they intended to rollover the distribution which Mr. Kopty received in 1998 from the J.D. Edwards & Co. ESOP. Further, they do not deny that Mr. Kopty delivered his J.D. Edwards & Co. stock certificate to Norwest on August 4, 1998. What they argue is that when Mr. Kopty hand- delivered the stock certificate to Norwest on August 4, 1998, he intended to give the certificate to Norwest only for safekeeping, pending the reissuance of the stock without restriction and its sale. Petitioners assert that Norwest made a mistake by depositing the stock into petitioner’s IRA before October 2, 1998, the date on which petitioner executed the Norwest form entitled “Self-Directed IRA Rollover/Direct Rollover Documentation”. One problem we have with this factual contention is that there is nothing in the record, other than petitioners’ testimony, to substantiate it. Certainly, Mr. Kopty did nothing to call this alleged mistake to the attention of the NorwestPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: March 27, 2008