Charlotte and Charles T. Gee v. Commissioner

127 T.C. No. 1

UNITED STATES TAX COURT CHARLOTTE AND CHARLES T. GEE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8755-05. Filed July 24, 2006. P rolled over a distribution from her deceased husband’s individual retirement account (IRA) into her separate IRA upon her husband’s death. Four years later, P received a distribution from her IRA. She claims that the distribution was an amount received from her deceased husband’s IRA and therefore exempt from the 10-percent additional tax on early distributions under sec. 72(t)(2)(A)(ii), I.R.C., as a distribution to a…