Writer Unhappy About Recharacterization Earnings Calculation
Writer Unhappy About Recharacterization Earnings Calculation
- AuthorsKidd, Wesley E., II
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Index TermsIRAsRoth IRAs
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2000-30620 (1 original page)
- Tax Analysts Electronic Citation2000 TNT 232-35
=============== SUMMARY ===============
Wesley E. Kidd II of Glen Ellyn, Ill., has complained about double taxation resulting from the recharacterization of Roth IRA funds moved into a rollover IRA using the method of calculating earnings set forth in Notice 2000-39, 2000-30 IRB 1. (For the full text of the notice, see Doc 2000-18655 (7 original pages) or 2000 TNT 133-1 .)
=============== FULL TEXT ===============
November 8, 2000
Subject: Complaint of Double Taxation
To: CC:DOM:CORP:R (Notice 2000-39)
Room 5226
Internal Revenue Service
POB 7604, Ben Franklin Station
Washington, DC 20044
Securities & Exchange Commission (SEC)
10 S. LaSalle St., 20th Floor
Chicago, IL. 60603-1002
Fidelity Investments Inc.
82 Devonshire Street
Boston, MA. 02109
1. Reference: IRS Notice 2000-39 contained in IRS Bulletin 2000- 30, Subject: Earnings Calculation for Returned or Recharacterized IRA Contributions, dated July 24, 2000.
2. In conjunction with a recharacterization of 450 shares of AT&T on October 31, 2000, Fidelity Investments moved certain other funds from my Roth IRA to my Rollover IRA thereby subjecting me to double taxation on the amount of those funds, i.e., in addition to the 450 shares of AT&T, Fidelity moved the following funds: (1) approximately $2,000 of a $16,000 Certificate of Deposit (CD) with the First Capital Bank of Georgia (11/3/99 - 11/3/00) (6.25%), (2) approximately $125 of the approximate $1000 interest earned on this CD, and (3) approximately $900 which represents the majority of my Janus fund (JAGIX). These Roth IRA funds represent money for which I have either already paid federal income taxes or am in the process of paying such taxes for the years 1998-2001. Fidelity's action represents a penalty in that when I eventually withdraw these funds from my Rollover IRA, I will have to pay ordinary income taxes again on the same money at the 28% rate (approximately $800). In other words, I will be taxed twice. There should be no such tax penalty for requesting a simple recharacterization of 450 shares of AT&T, simply because those shares dropped in value during the conversion period of five (5) months. The "old method" of calculating net income, mentioned in the above reference, results in no such penalty because it did not reflect losses of the IPA during the time it held the contribution whereas the "new method" does.
Wesley E. Kidd II
Glen Ellyn, Illinois
- AuthorsKidd, Wesley E., II
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Index TermsIRAsRoth IRAs
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2000-30620 (1 original page)
- Tax Analysts Electronic Citation2000 TNT 232-35