IRCCourt RulingsDec 2, 2010related by meaning
… Tax Under Section 72(t) on the
Distribution From Petitioner's Retirement Plan
In general, section 4974(c) defines qualified retirement
plans as including individual retirement accounts (IRA). Section
408 governs the treatment of IRAs. Specifically, section 408(d)
provides that distributions from an IRA are generally t…
IRCPrivate Letter RulingsMar 16, 2012
974. If the Plan is modified, this ruling will not necessarily remain applicable.
This ruling is directed onl y to Employer and applies to the Plan as submitted by a transmittal letter dated March 7, 2011, and the provisions of the
amended and restated version provided on October 26, 2011. Section
6110(k)(3) of the Cod…
IRCCourt RulingsOct 11, 1957
…f ownership and control of the policy belong to her. Annual premiums on the Prudential policy were $974,40 for the first 3 years and $1,137.30, thereafter.
On April 5,1941, Bessie, as “applicant,” and Clarence, as the proposed insured, made application to the John Hancock Mutual Life Insurance Company of Boston, Massac…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
IRCCourt RulingsNov 21, 2023
…104 (4th Cir. 1995); Pro . & Exec. Leasing,
Inc. , 89 T.C. at 232; Simpson v. Commissioner, 64 T.C. 974, 984– 85 (1975) .
17
[* 17] and Arjun. The record establishes that petitioners pursued that
goal. Although Veerendra and Arjun were in college in 2014, petitioner
husband credibly recounted assigning them research ta…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
IRCCourt RulingsJan 4, 2011
… tax treatment:under section
501(a)). In addition, 'the Employee Retirement Income Security
Act of 1974, Pub. L. 93-406,- sec. 402(a) (1) 88 Stat. 875;
requires that the plan be in writing. See also sec.
1.401-1(a) (2), Income Tax"Regse Congress established the writing
requirement-so that every employee may, -on examin…
IRCCourt RulingsSep 23, 2019related by meaning
or the taxing
authority that imposed the levy. Petitioners have not shown that they are eligible
for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a
loan which they used to purchase a home in Vermont in 2013. Petitioners
provided only Form 1099-…
IRCCourt RulingsApr 14, 2005
…1988); Burnetta v.
Commissioner
, 68 T.C. 387, 397 (1977); Simpson v. Commissioner
,
- 16 -
64 T.C. 974, 984 (1975); Packard v. Commissioner
, 63 T.C. 621,
629 (1975); sec. 1.1402(c)-1, Income Tax Regs.
Relevant factors courts consider to determine whether an
employer/employee relationship exists between the service
pr…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
IRCCourt RulingsFeb 15, 2002related by meaning
tioner’s 1998
Federal income tax and an addition to tax under section
6651(a)(1) of $3,433 and $321, respectively. After concessions
by the parties,
2 the issues are (1) whether petitioner is liable
for the additional tax under section 72(t) and (2) whether
petitioner is liable for the addition to tax under section
665…
IRCCourt RulingsJan 16, 2020related by meaning
…tax of 10% on the portion of a
distribution from a qualified retirement plan as defined in section 4974(c) (e.g., an
IRA) that is includable in gross income, unless the distribution falls under one of
the exceptions prescribed in section 72(t)(2). Petitioners assert that the additional
IRCCourt RulingsDec 19, 1995
…ove factors must be shown by a preponderance
of the evidence. Armes v. Commissioner
, 448 F.2d 972, 974 (5th
Cir. 1971), affg. in part and revg. T.C. Memo. 1969-181.
We explained the mechanics of how the burden of going
forward with the evidence works and when it shifts in Adler v.
Commissioner
, 85 T.C. 535, 540 (1985…
IRCCourt RulingsJul 29, 1997related by meaning
…ional tax of 10 percent of
amounts received from qualified retirement plans (as defined in
section 4974(c)) that are includable in gross income. Section
72(t)(2) contains certain exceptions. Respondent determined that
such additional tax was due from petitioner on account of his
receipt of the 1992 distribution and the…
IRCCourt RulingsMay 21, 1999
… 655
Office expense 1,485
Travel 2,156
Other expenses:
Beeper, phone $849
Subscriptions & law books 974
Clothing, shoes & maintenance 728
Seminars 593
Continuous legal education
& examination fees 1,935
5,079
Total
14,897
Schedule C: "Clothing And Accessories"
Cost of goods sold $3,128
Expenses:
Advertising 455
Supplie…
IRCCourt RulingsMar 24, 1980
…24 241,922
Profit-sharing 9,161.48 13,960.19 19,348.99 27,238 36,032
Total 71,232.48 108,307.69 149,974.93 210,862 277,954
IRCCourt RulingsJul 22, 1999
…ceived a retirement account
distribution from Common Sense Shareholder Services in the amount
of $1,974. Mr. Morin had not yet attained the age of 59½ at the
time he received this distribution.
OPINION
Section 61 defines gross income as all income from whatever
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015
…ity, Inc., docket No. 11520-11
Accuracy-related penalty
Year Deficiency Sec. 6662(a)
2006 $9,872 $1,974
2(...continued)
dollar. We interchangeably use the terms "insurance contract" and "insurance
policy" for convenience and do not intend to signify a distinction by our use of
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1996-450
UNITED STATES TAX COURT
THEODORE SOURIS, P.C., A DISSOLVED CORPORATION,
AND THEODORE SOURIS, AS SUCCESSOR IN INTEREST
OF THEODORE SOURIS, P.C., Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 639-95. F…