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21. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001
    … shares of Burien Nissan stock and Mr. Whitehead became the sole stockholder of Burien Nissan. Form 1120, U.S. Corporation Income Tax Return (Form 1120), that Burien Nissan filed for each of its tax years 1994 through 1997 showed Mr. Whitehead as the sole stockholder of Burien Nissan. Mr. Whitehead signed as president …
22. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …n's benefit was $467,600. F. Tax Return Information 1. Our Country a. 2005 Our Country filed a Form 1120, U.S. Corporation Income Tax Return, for 2005. In that return Our Country claimed a $450,000 deduction for "employee benefit programs". Our Country did not disclose its participation in the Sterling Plan. Our Countr…
23. 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…
24. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023
    …e pursuant to section 280A(g). JYJ reported the marketing fees it had received from KJJJ on F orm s 1120, U.S. Corporation Income Tax Return , for its taxable years ending November 30, 2 01 5 , 201 6 , 201 7 , and 2018. 11 Besides the marketing fees from KJJJ , JYJ did not report any income. It did not claim any deduct…
25. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    moot, or irrelevant . To reflect the foregoing, Decision will be entere d for respondent . 8Sec . 6654(e) provides two exceptions to the sec . 6654(a) addition to tax . First, the addition is not applicable if the tax shown on the taxpayer's return for the year in question (or, if no return is filed, the taxpayer's tax…
26. T.C. Memo. 2000-171 — Van Roekel Farms, Inc. v. Commissioner
    IRCCourt RulingsMay 24, 2000
    …ly, for each of those years, petitioner deducted $2,250, $2,700, and $2,550, respectively, on Forms 1120, U.S. Corporation Income Tax Return, as payments to the plan on behalf of Mr. Van Roekel. As shown below, petitioner reported no deduction for salaries, wages, or officers’ compensation but deducted management fees …
27. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
28. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
29. T.C. Summary Opinion 2001-148 — Patrick L. O'Brien v. Commissioner
    IRCCourt RulingsSep 21, 2001related by meaning
    , disability, a series of periodic payments, separation from service after attaining the age of 55, or for the purpose of medical expenses. Petitioner contends that the distribution is not subject to the section 72(t) additional tax because the distribution was made pursuant to a qualified domestic relations order. Sec…
30. 72 T.C. 768; 1 Employee Benefits Cas. (BNA) 1603 — Guest v. Commissioner
    IRCCourt RulingsAug 3, 1979related by meaning
    to a reasonable concern of Congress. Thus section 219(b)(2) does not create an unconstitutional presumption. II. Liability for Section U973 Excise Tax Petitioners argue that, if we uphold the constitutionality of section 219(b)(2), then the 6-percent excise tax imposed by section 4973 cannot be imposed because there ar…
31. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    tions. Sec. 72(t)(3)(A). or after the death of the employee; (3) attributable to the employee's being disabled within the meaning of section 72(m)(7); (4) part of a series of substantially equal periodic payments (not less frequently than annually) made for the life (or life expectancy) of the employee or joint lives (…
32. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013related by meaning
    ed CST, an entity owned by his IRA, to enter into a lease agreement with CDJ, an entity owned by both petitioners and their children in tax year 2006. The notice of deficiency also reflected respondent's determination that, for the year in which the prohibited transaction occurred petitioners are liable for the additio…
33. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ble. Zmuda v. Commissioner , 79 T.C. 714, 727 (1982), affd. 731 F.2d 1417 (9th Cir. 1984). In this instance, petitioner readily admits that A Atlantic is presently holding his property, and that there is a - 9 - 7 For the purposes of sec. 72(t), the term "employee" also refers to participants in individual retirement a…
34. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
35. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    x Return, Brownsville Medical aÑd Brownsville Apothecary's Forms 1120, U.S. Corporation Income Tax Return, and Cost Plus' Forms 1120S, U.S. Income Tax Return for an S Corporation, for years 1998 through 2006. - 9 - Morris A. Goldstein (M. Goldstein) and Sidney Goldstein (S. Goldstein) are Tennessee C.P.A.s practicing w…
36. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    foregoing statutory - 19 - requirements were satisfied for the audit year. Therefore, we reject petitioner’s claim, raised at trial, to deductions for three dependency exemptions. VI. Respondent’s Section 72(t) Determination Section 72(t) provides, in pertinent part, as follows: SEC. 72(t). 10-Percent Additional Tax on…
37. 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 …
38. T.C. Memo. 1999-161 — Roblene, Inc. v. Commissioner
    IRCCourt RulingsMay 13, 1999
    …s for the years ended July 31, 1987, through 1990. Petitioner's corporate income tax returns, Forms 1120, for the years that ended July 31, 1987, through 1990, indicate that the compensation paid to the officers for each year was zero dollars. These returns also indicate that during the - 13 - same period the salaries …
39. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
40. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    ibution was not from an IRA, it would not qualify for the exception for higher education expenses, even if it were used for higher education expenses. Petitioners stated in their petition that the distribution was from a section 401(k) account, a fact which petitioners have not denied. Petitioners did not respond to th…