-12-
accordance with section 1.401(a)(9)-1, Proposed Income Tax Regs.,
52 Fed. Reg. 28075 (July 27, 1987). According to the single life
expectancy table in section 1.401(a)(9)-9, Q&A-1, Income Tax
Regs., the life expectancy of a 48-year-old person is 36 years.
Finally, using traditional methods of financial calculation,
we believe that annual payments of $26,154.16 would have to be
made to amortize $286,000 over 27 years at 8 percent interest.
According to our calculation, we also believe that annual
payments of $24,408.58 would be necessary in order to amortize
$286,000 over 36 years at 8 percent interest.
As stated above, petitioner claims that the subject
distribution of $25,000 from his IRA in the OCTFCU is a part of
the series of substantially equal periodic payments that began in
2001. He claims to have computed this amount using the fixed
amortization method described by Notice 89-25, supra.
Under the fixed amortization method described by Notice 89-
25, supra, the amount of the periodic payment, once computed,
does not change. The amount is "fixed” and is distributed from
the taxpayer's retirement account at each chosen period
thereafter ("not less frequently than annually”). See Notice 89-
25, supra.
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