5-78-Tax20Research20Memo20No.201_fhakim_FILE20MEMORANDUM

5-78-Tax20Research20Memo20No.201_fhakim_FILE20MEMORANDUM -...

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Unformatted text preview: TAX 6684 Federal Tax Research Tax Research Memo Assignment 1 TR 5-78 Faisal Hakim Ti Su 08/30/2010 F I LE M E MORANDU M August 27, 2010 To: File From: CPA Re: Amount of Tax on Distribution of IRA Facts: Cecilia died this year, owning mutual funds in her IRA worth $120,000. Under the terms of the IRA, Cecilias surviving husband, Frank, was the beneficiary of the account, and he took a lump-sum distribution from the fund. Both Cecilia and Frank were age fifty-seven at the beginning of the year. Issues: What are the tax consequences to the spouse beneficiary of the lump-sum distribution from the decedent's IRA? And what are the tax consequences if the beneficiary is nonspouse?Whether a spouse beneficiary of a lump-sum distribution from decedent wifes IRA can avoid taxation on the distribution if husband and wife were both 57 years old. Whether a non-spouse beneficiary of a lump-sum distribution from decedents IRA can avoid taxation on the distribution. What time restrictions and what marital deduction? Explain. What requirement? ??? What is a rollover contribution and what does (A) and (B) state? Need to explain the context of this and how it relates to the issue. paying Provide source for estate tax marital deduction. The beneficiary is not attempting to deduct any contributions. He is t rying to avoid taxation on distributions. Again, the beneficiary is not attempting to deduct any contributions. He is t rying to avoid taxation on the distributions. The spouse already received the deduction for the contributions previously. Need to explain the relevance of the taxpayers age. ??? Discuss the requirements Need to explain what you mean by some requirement met. Significance? ..your spouses.. marital have Conclusion: Frank is allowed to exclude the distribution from his gross income and to not pay tax on the rollover of an inherited IRA because of the time restrictions and the marital deduction are met. Whether a spouse beneficiary of a lump-sum distribution from decedent wifes IRA can avoid taxation on the distribution if husband and wife were both 57 years old. Whether a non-spouse beneficiary of a lump-sum distribution from decedents IRA can avoid taxation on the distribution. What time restrictions and what marital deduction? Explain. What requirement? ??? What is a rollover contribution and what does (A) and (B) state? Need to explain the context of this and how it relates to the issue. paying Provide source for estate tax marital deduction. The beneficiary is not attempting to deduct any contributions. He is t rying to avoid taxation on distributions. Again, the beneficiary is not attempting to deduct any contributions. He is t rying to avoid taxation on the distributions. The spouse already received the deduction for the contributions previously....
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5-78-Tax20Research20Memo20No.201_fhakim_FILE20MEMORANDUM -...

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