What simplifying assumptions will be used to resolve the Notice 2004-8 transaction?
A.1 For the limited purpose of resolving the Notice 2004-8 transaction under Announcement 2005-80, various simplifying assumptions will be used to determine the amount of tax that must be paid. The following simplifying assumptions are for cases in which the Roth IRA does not predate the Notice 2004-8 transaction, did not receive any rollover contributions from another Roth IRA or conversion contributions, and did not make any distributions that were rolled over to another Roth IRA. Thus, all assets must be disgorged from the Roth IRA and are not eligible for rollover treatment. Appropriate adjustments will be made in those cases involving pre-existing Roth IRAs, rollover contributions from another Roth IRA, conversion contributions, or distributions that were rolled over to another Roth IRA. All contributions to the Roth IRA will be treated as made on June 30, 2003. All distributions from the Roth IRA will treated as made on December 31, 2004, except that actual distribution dates wil
