Michael J. Kulzer & Jan K. Bielman-Kulzer - Page 13




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          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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