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Losses on a closed-down Roth IRA can be claimed as a miscellaneous itemized deduction, subject to the 2%-of-AGI offset. However, if you cash out that poorly-performing Roth within the first five years of its existence and haven't reached age 59 1/2 nor do you qualify for any other exception, you must pay a 10% penalty. The 10% penalty is computed on the amount you cashed out less any annual contributions you made.
Source: The Kiplinger Tax Letter November 8, 2002
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