- 2 - The issue for decision is whether petitioners are entitled to recover from respondent $7,253 in administrative costs relating to petitioners’ claim for refund of $13,769 in overpaid 2001 Federal income taxes. Hereinafter, all references to petitioner in the singular are to petitioner Morton Kwestel. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time the petition was filed, petitioners resided in Rockaway, New Jersey. In 2001 petitioner converted a traditional IRA into a Roth IRA under section 408A(d)(3). For 2001, petitioners timely filed their joint Federal income tax return and paid the tax shown due thereon. On their return as filed, petitioners included in income the $55,065 in accumulated untaxed IRA earnings.1 On October 14, 2002, petitioner timely reversed the conversion of his Roth IRA back into a traditional IRA under section 408A(d)(6).2 1Under sec. 408A(d)(3)(A) and (C), upon conversion of a traditional IRA into a Roth IRA, the amount of untaxed earnings in the IRA is includable in the taxpayer’s taxable income in the year of the conversion. 2Under sec. 408A(d)(6), a conversion of a traditional IRA into a Roth IRA may be reversed so long as the transfer of funds reversing the conversion is completed by the tax return filing (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007