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1. T.C. Summary Opinion 2006-11 — Richard Bradley v. Commissioner
   IRCCourt RulingsJan 26, 2006
   …ection 7491(a)(2). Therefore, the burden of proof remains with petitioner. II. Distributions of $15,322.69 and $7,000 A. General Section 408(d)(1) provides that any amount paid or distributed from a qualified retirement plan generally must be included in gross income by the distributee in the manner provided under sect…
2. Treas. Reg. § 1.72(p)-1(b) — Loans treated as distributions.
   IRCRegulationsSep 17, 2024
   …the new loan is $40,000, the outstanding balance on January 1, 2006, of the loan it replaces is $33,322, and the highest outstanding balance of loans from the plan during 2005 was $40,000. Accordingly, under section 72(p)(2)(A), the sum of the new loan and the outstanding balance on January 1, 2006, of the loan it repl…
3. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
   IRCCourt RulingsJul 31, 2000
   …e end of that year, the conversion credit balance was $7,485.21 ($4,865.74 + $2,962.50 - $665.36 + $322.33); the $322.33 is the interest of 4.5 percent earned on the conversion credit balance (($7,485.21 - $322.33) x 4.5% = $322.33)). Of the conversion credit balance, $6,755.40 could have been transferred at this time …
4. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
   IRCCourt RulingsMar 16, 1999★ strong match
   itioner and his wife owned 100 percent of the Garrahan Agency, and since petitioner is a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G). 3. Conclusion The Garrahan Agency is a disqualified person under section 4975(e)(2), and thus it and petitio…
5. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
   IRCCourt RulingsAug 8, 1996related by meaning
   to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
6. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
   IRCCourt RulingsJan 30, 2007
   …ll Lynch, to protect Taxable income Cash Pay 123,000 Merrill Lynch, to protect Taxable income Other 322,962 Merrill Lynch, to protect Taxable income Total 1,118,870 Petitioners reported taxable income of $213,977, tax of $60,080, tax on IRAs and other retirement plans of $63,717, and total tax 4(...continued) 2000. - 1…
7. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
   IRCCourt RulingsAug 6, 1991related by meaning
   f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
8. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
   IRCCourt RulingsFeb 18, 1997related by meaning
   l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
9. 72 T.C. 768; 1 Employee Benefits Cas. (BNA) 1603 — Guest v. Commissioner
   IRCCourt RulingsAug 3, 1979related by meaning
   155. Decisions will be entered for the respondent in docket Nos. 6173-77 and 11438-77. Decision will be entered under Rule 155 inI docket No. 9115-77. Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954, as in effect for the taxable year in issue. Respondent concedes …
10. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
11. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …iding for it by statute. See, e.g., secs. 1(f), 151(d)(4); Bartley v. Commissioner, T.C. Memo. 1998-322 n.10. - 7 -
12. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
13. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
14. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006
    …ommissioner , T.C. Memo. 1999-15. In contrast, in Estate of Fontana v. Commissioner , 118 T.C. 318, 322 (2002), the Tax Court concluded that property held in a marital trust created by decedent’s spouse that was subject to decedent’s testamentary general power of appointment was to be aggregated with property owned out…
15. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
16. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    ement of this title, including all rules and regul ations as may be necessary by reason of any alteration of law in relation to internal revenue.” 108 Section 7805(b) of the Internal Revenue Code of 1954, 68A Stat. at 917, was the provision in the Internal Revenue Code of 1954 that was analogous to section 3791(b) of t…
17. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
18. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …c. v. NLRB , 788 F.2d 586, 590 (9th Cir. 1986); Continental Web Press, Inc. v. NLRB , 767 F.2d 321, 322-323 (7th Cir. 1985). To demonstrate that they each had a net worth of less than $2,000,000 on the date their petition was filed, petitioners submitted, on August 1, 1994, a "STATEMENT OF NET WORTH AT ACQUISITION COST…
19. T.C. Memo. 1997-487 — Richard Walter Drake v. Commissioner
    IRCCourt RulingsOct 28, 1997
    …as petitioner's home and office. Respondent allowed petitioner a deduction for office expense of $5,322 and allowed petitioner Schedule A deductions totaling $5,322. Respondent disallowed the remaining expense claimed on petitioner's Schedule E with the 5 exception of supplies in the amount of $78. As a result of these
20. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020related by meaning
    sis test. FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose. Sandra M. Conard, pro se. Scott W. Forbord and Mark J. Miller, for respondent. OPINION TORO, Judge: A taxpaye…