| APPENDIX CAdditional Checklist for Roth IRA Recharacterization Ruling Requests |
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In order to assist EP Technical in processing a ruling request involving a Roth IRA recharacterization, in addition to the
items in Appendix B, please check the following list.
|
| Yes No N/A Page |
1. Did you include the name(s) of trustee and/or custodian of the traditional individual retirement account (IRA) (generally,
a financial institution)?
|
| Yes No N/A Page |
2. Is each IRA identification number present? |
| Yes No N/A Page |
3. If the ruling request involves Roth conversions both of a husband and wife, is the necessary information with respect
to each IRA of each party present? Note: as long as husband and wife file a joint federal Form 1040, the Service can issue
one ruling covering both parties. Furthermore, if a joint federal income tax return has been filed for the year or years
in question, the Service only requires one user fee even if both husband and wife had failed conversions.
|
| Yes No N/A Page |
4. If there was one or more attempted conversions, are the applicable dates on which the attempted IRA conversion(s) occurred
included?
|
| Yes No Page |
5. If the reason that a conversion failed is that the taxpayer or related taxpayers relied upon advice of a tax professional
such as a CPA, an attorney, or an enrolled actuary, is the name and occupation of that adviser included?
|
| Yes No Page |
6. Is certification that the taxpayer or taxpayers timely filed the relevant federal tax return(s) present? |
| Yes No Page |
7. Is there a short statement of facts with respect to the conversion? For example, if the ruling request involves a conversion
attempted in 1998, there should be a statement of the facts that includes a representation of why the due date(s) found
in Announcement 99-57 and Announcement 99-104 were not met.
|
| Yes No Page |
8. If the taxpayer recharacterized his/her Roth IRA to a traditional IRA prior to submitting a request for § 9100 relief,
are the date(s) of the recharacterization(s), name(s) of trustees and/or custodians, and the identification numbers of
the traditional IRA(s) present?
|
| Yes No Page |
9. Does the request include the type of contribution (i.e., regular or conversion) and amount of the contribution being
recharacterized?
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