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and properly treated under section 408A(d)(6) petitioner’s IRA
earnings as not includable in petitioner’s 2001 income.
On September 17, 2003, respondent’s Compliance Division
mailed to petitioners a certified formal disallowance letter
disallowing petitioners’ $13,769 refund claim for 2001.
On December 16, 2003, in response to petitioners’
accountant’s September 4, 2003, letter, the Employee Plans
Technical Branch of respondent’s National Office faxed to
petitioners’ accountant a letter indicating that petitioner was
to be treated as timely reversing the conversion of his
traditional IRA into a Roth IRA.
On December 18, 2003, petitioners filed with respondent a
duplicate 2001 amended Federal income tax return, attaching to
this return a copy of the Employee Plans Technical Branch
December 16, 2003, favorable letter.
On April 2, 2004, respondent’s Compliance Division mailed to
petitioners a letter reversing its earlier position and allowing
in full petitioners’ $13,769 refund claim. On May 24, 2004,
respondent mailed to petitioners a check in the amount of $14,921
consisting of petitioners’ claimed tax refund plus interest.
On or about August 1, 2004, petitioners mailed to respondent
their claim under section 7430 for $7,253 in administrative costs
relating to their attempt to resolve the question as to the
taxability of their IRA conversion and the reversal thereof.
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Last modified: November 10, 2007