| APPENDIX C |
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| Additional 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.
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| Yes No N/A Page |
1. Did you include the name(s) of the
trustee and/or custodian of the traditional individual retirement account
(IRA) (generally, a financial institution)?
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| Yes No N/A Page |
2. Is each IRA identification number
present?
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| 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.
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| 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?
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| 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?
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| Yes No Page |
6. Is certification that the taxpayer
or taxpayers timely filed the relevant federal tax return(s) present?
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| 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.
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| 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?
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| 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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