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41. 127 T.C. No. 1 — Charlotte & Charles T. Gee v. Commissioner
    IRCCourt RulingsJul 24, 2006related by meaning
    erefore no longer qualify for the exception . The section 72(t) tax discourages premature IRA distributions that frustrate the intention of saving for retirement . Dwyer v . Commissioner , 106 T .C . 337, 340 (1996) ; see also S . Rept . 93-383, at 134 (1974), 1974-3 C .B . (Supp .) 80, 213 . To avoid the section 72(t)…
42. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…
43. 89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities
    IRCFinal Rules (FR)Apr 25, 2024related by meaning
    )(i), as contained in 26 CFR part 1, revised as of April 1, 2024. Douglas W. O'Donnell, Deputy Commissioner. Approved: April 2, 2024. Aviva Aron-Dine, Acting Assistant Secretary of the Treasury (Tax Policy). Footnotes 1.  PLR 200923001 (February 26, 2009). Back to Citation 2.   See also STAFF OF THE JOINT COMM. ON TAX'…
44. T.C. Summary Opinion 2009-156 — Dean Gochis v. Commissioner
    IRCCourt RulingsOct 13, 2009related by meaning
    Section 72(t) Additional Ta x Section 72(t) imposes an additional tax on an individual retirement plan distribution equal to 10 percent of the amount .included in gross income, subject to certain exceptions . Because the ASLAC distribution is not includable in petitioner's gross income, petitioner is not liable for th…
45. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    ho conducted petitioner's CDP hearing, a USPS document relating to the notice of deficiency for 2012, and a copy of this Court's order and decision in Wesley v. Commissioner, docket No. 6560-14L. At trial petitioner offered and we admitted into evidence a screen shot of information he had downloaded from the USPS track…
46. U.S. Tax Court — Anna E. & Mark S. Warrington v. Commissioner
    IRCCourt RulingsJul 19, 2007related by meaning
    g, 290 U .S . 111, 115 (1933) . 2 Section 72(t) provides for an additional tax where a person under the age of 59-1/2 withdraws money from a qualified retirement account, unless that person falls within an enumerated exception . Section 72(t)(1) and (2) provides in relevant part : SEC . 72(t) . 10-Percent Additional Ta…
47. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    re to pay his 2004 taxes; and (4) whether the Court should impose a penalty under section 6673 for petitioner's advancement of frivolous or groundless arguments in proceedings instituted primarily for protest or delay. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of the par…
48. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
    tion or Section 4947(a)(1) Trust Treated as Private Foundation, if the organization is required to file at least 250 returns during the calendar year. Section 6011(e)(4) was added to the Code in 2010 by section 522, Title V, of the Hiring Incentives to Restore Employment (HIRE) Act, Public Law 111-147, 124 Stat. 71, to…
49. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
50. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    Court, the two cases were consolidated for hearing on the motions to dismiss. The hearing was held on November 29, 2004, in San Francisco, California. Discussion Section 6033(a)(1) requires an organization exempt from taxation under section 501(a) to file."an annual return, stating specifically the ite s of gross incom…
51. T.C. Memo. 2026-93 — Aloke Pal v. Commissioner
    IRCCourt RulingsSep 24, 2026related by meaning
    e age of 59 1/2 during 2021. And he does not c on tend that any of the other exceptions in section 72(t)(2 ) applies . We will accordingly sustain the IRS’s determination of a $ 22,986 additional tax for 2021. IV. Penalty The Code imposes a 20% penalty upon the portion of any underpayment of income tax required to be s…
52. 85 FR 27693 — Effect of Section 67(g) on Trusts and Estates
    IRCProposed Rules (FR)Proposed May 11, 2020related by meaning
    ies). Other personnel from the Treasury Department and the IRS, however, participated in their development. Statement of Availability of IRS Documents The IRS notice cited in this document is published in the Internal Revenue Bulletin and available from the Superintendent of Documents, U.S. Government Publishing Office…
53. 75 FR 8796 — Civil Penalties Under ERISA Section 502(c)(8)
    ERISAFinal Rules (FR)Feb 26, 2010related by meaning
    nsenting party shall have fifteen (15) days to file any objections to the proposed settlement with the administrative law judge and all other parties; (3) If any party submits an objection to the proposed settlement, the administrative law judge shall decide within 30 days after receipt of such objections whether he sh…