(2) he sought to but was unable to obtain complete supporting documents for the years 1975-1986, (3) the figures are documented in part by past tax returns which comport with Debtor's testimony, and (4) Debtor's expert Mr. Fife used a reasonable method to calculate the contributions and interest thereon. 5 . § 522(b)(3)(C); § 522(d)(12). 6 . § 522(b)(4)(B)(i)-(ii). 7 . Although Wilson’s declaration does not attest to whether the IRA was in substantial compliance on the date of the bankruptcy petition, which is the operative date for purposes of this analysis, the parties did not raise this as an issue. 8 . 26 U.S.C. § 408(d) deals with the tax treatment of distributions and will be discussed in the next section. 9 . See Michel v. C.I.R., 58 T.C.M. (CCH) 1019, 1989 WL 154252 (T.C.1989) (<HOLDING>). 10 . The distinction can be found in the IRC
recognizing a right to contribution holding that the subsequent tax treatment of an ira contribution does not affect the validity of the ira holding that shepard did not affect the continuing validity of almendareztorres holding that a defective acknowledgment does not affect the validity of a mortgage as to the parties holding that the invalidity of a provision for a de novo trial in superior court in the appeal section of an act did not affect the validity of the remainder of the appeal section