United States Federal Circuit

26 USC 408A(d)(3)(F)(i) (Supp. V 1999) of the Internal Revenue Service Restructuring and Reform Act of 1998, which imposed the early withdrawal penalties for IRA's to Roth IRA's retrospectively to rollover transfers to that occurred before its effective date does not violate due process.

Appellate Information

• Decided 01/10/2002
• Published 01/11/2002

Judges

• Before MICHEL, Circuit Judge, FRIEDMAN, Senior Circuit Judge, and RADER, Circuit Judge.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• Nancie C. Marzulla, Defenders of Property Rights, of Washington, DC, filed a combined petition for rehearing and rehearing en banc for plaintiffs-appellants.   With her on the brief was Roger J. Marzulla.


• For Appellees:
  
• Steven W. Parks, Attorney, Tax Division, Department of Justice, of Washington, DC, for defendant-appellee.