Nipps v. Comr., T.C. Memo. 2011-267

(petitioner inherited funds from non-spousal IRA and transferred funds into IRA; on same day of transfer, petitioner withdrew contributed funds; no valid trustee-to-trustee transfer made and petitioner subject to income tax on distributions from IRA; no accuracy-related penalty imposed because petitioner believed that bank holding IRA account would make correct withholding and petitioner not experienced in tax law).

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