Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 42 T.C. 628 (not yet in the library — opens the official source)
83 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2015-60 — Cheryl Lynn Ireland v. Commissioner
    IRCCourt RulingsOct 1, 2015related by meaning
    ioner, 106 T.C. 337, 340 (1996) (citing and discussing the legislative history underlying section 408(f), the statutory predecessor to section 72(t)); Milner v. Commissioner, T.C. Memo. 2004-111. Section 72(t)(2)(B) provides an exception to the imposition of additional tax to the extent that retirement plan distributio…
  2. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    …ommissioner , 820 F.2d 1543, 1549 (9th Cir. 1987), affg. T.C. Memo. 1986-23), affg. T.C. Memo. 1987-628. This two-part test, however, is not - 30 -
  3. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  4. 81 T.C. 652; 81 T.C. No. 38 — Doty v. Commissioner
    IRCCourt RulingsSep 28, 1983related by meaning
    nstituted earned income, thereby entitling her to the benefits of section 1348 during the tax years in issue. Decision will be entered under Rule 155. Sec. 1348 was repealed by the Economic Recovery Act of 1981. Pub. L. 97-34, sec. 101(c)(1), 95 Stat. 172,183. Specifically, the marriage settlement agreement provides: "…
  5. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    b) (2) and 72. See Chevron U.S.A. Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 842-843 (1984). II. Application of Sections 402(b) (2) and 72 Because we have found that section 402(b) (2) controls the tax consequences of the policy distributed to petitioners, -we now turn our attention to that section to deter…
  6. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
  7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    that the Court vacate its Order [sic] of August 16 and order the parties to submit computations pursuant to Rule 155. This will permit the parties the opportunity to determine whether TLC's liability should be reduced by the amounts already paid by parties to the transaction. On the record before us, we reject petition…
  8. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  9. PLR 200521012 — Special Rules for Pensions, Annuities, and Certain Other Deferred Income
    IRCPrivate Letter RulingsMay 27, 2005
    …tions portion of a distribution from a United States plan in Clayton v. United States , 33 Fed. Cl. 628 (1995), aff'd without published opinion , 91 F.3d 170 (Fed. Cir.), cert. denied , 519 U.S. 1040 (1996). Section 501(a) provides, in relevant part, that an organization described in section 401(a) generally is exempt …
  10. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  11. 148 T.C. No. 22 — Steven M. Petersen & Pauline Petersen v. Commissioner
    IRCCourt RulingsJun 13, 2017
    …revised that treatment in 1978 by enacting section 267(e). Act of November 10, 1978, Pub. L. No. 95-628, sec. 2(a), 92 Stat. at 3627. Section 267(e) provides that, for purposes of applying subsection (a)(2), an S corporation and "any person who owns (directly or indirectly) any of the stock of such corporation" shall b…
  12. 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…
  13. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
  14. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …June 30, 1989 9,725,667 9,759,287 June 30, 1990 11,111,080 11,111,080 June 30, 1991 3,224,665 2,237,628 BI's transition from providing services only to local merchants, service stations, and banks, to serving some large companies was gradual. During the years here involved and for some years prior to those here involve…
  15. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
  16. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    payer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax under this chapter 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 which is includible in gross income. - 9 - 5 See also …
  17. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJun 10, 1996
    …ican Trucking Associations, Inc. , supra ; Centel Communications Co. v. Commissioner , 92 T.C. 612, 628 (1989), affd. 920 F.2d 1335 (7th Cir. 1990). The relevant language in section 415(b)(5) includes "In the case of an employee who has less than 10 years of service with the employer". There is no dispute that the year…
  18. T.C. Memo. 2000-137 — Alton F. Emerson v. Commissioner
    IRCCourt RulingsApr 12, 2000
    …9. At the end of 1995, petitioner was age 57. In 1996, petitioner reported nontaxable income of $50,628 as sick pay, $29,500 in total IRA distributions, and $39,506 in total pensions and annuities. Respondent determined that the $39,506 in total pensions and annuities was attributable to petitioner's disability. Petiti…
  19. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    470 in petitioner's deductions, a $144 decrease in petitioner's withholding credits, and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent Spolse Relief, seeking equitable relief from liability under the provisions of section 66(c). Respondent determ…
  20. T.C. Memo. 2012-311 — Charles L. Hartley v. Commissioner
    IRCCourt RulingsNov 6, 2012related by meaning
    taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross mcome. Exceptions to this rule are found in section 72(t)(2). Petitioner has not identified any exception applicable to this case, nor have we. Regarding petitione…