IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
ioners filed their memorandum on February 12, 2014, and
(continued...)
- 63 -
As an exception to the general rule of section 1.61-22(b)(1), Income Tax Regs., an arrangement between an owner and a nonowner of a life insurance
contract is a split-dollar life insurance arrangement if it is either a compensatory
arrangemen…
IRCCourt RulingsJan 16, 2020related by meaning
bed in section 72(t) in respect of Mr. Merrell's IRA
distribution is sustained.
As a final matter, petitioners maintain that they will suffer economic hardship if the additional tax prescribed in section 72(t) is imposed in this case.
We have considered similar claims in the past and have observed that there is no
-8au…
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…
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…
IRCCourt RulingsJul 22, 1999related by meaning
ursuant to section 72(t).
- 6 -
Section 72(t) provides for a 10-percent additional tax on the
taxable amount of an early distribution from a qualified retirement plan. Section 72(t)(2) provides exceptions to the tax
for certain types of distributions. Petitioners did not offer
any evidence at trial related to this issu…
IRCCourt RulingsNov 4, 1998related by meaning
eafter received his SPB monthly.
Petitioner retains a valid chief engineer’s license issued
by the U.S. Coast Guard for standby use if needed by MEBA. On August 22, 1991, petitioner elected to forgo continued
health care coverage through MEBA Medical. Petitioner checked
option one and signed the election form discussed…
IRCCourt RulingsSep 18, 1996related by meaning
sents taxable
earnings from petitioner's IRA and that such amount is properly
includable in petitioners' gross income for 1990. Sec.
408(d)(1).
- 25 - In view of our conclusion, supra
, that petitioner's Transfer
Refund qualifies for tax-free rollover treatment in 1989 under
section 402(a)(5)(D), we understand petition…
T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred… IRCTreasury DecisionsFeb 6, 2006related by meaning
idance concerning the requirements for designated Roth contributions under qualified cash or deferred arrangements.
EMPLOYMENT TAX
T.D. 9239 T.D. 9239 Final, temporary, and proposed regulations under section 6011 of the Code relate to the time for employers to file returns and make deposits under the Federal Insurance …
89 FR 32346 — Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
nd in its text, PTE 2020-02 has been broadly amended to encompass compensation for advice irrespective of the product recommended.
Back to Citation
6. ERISA section 408(a) and Code section 4975(c)(2), expressly permit the Department (through the Reorganization Plan No. 4 of 1978) to grant “a conditional or uncondition…
IRCCourt RulingsAug 12, 1980related by meaning
.
Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…
IRCCourt RulingsJan 27, 1998related by meaning
articipants, Harold Breslow and Robert Levine,
received their full benefit and petitioner signed an irrevocable
waiver of his rights to Plan benefits. We reject petitioner's argument. Examining the record, we
find no documentary evidence that all rank and file employees
were paid their full vested interest, especially …
81 FR 21147 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Co… ERISAFinal Rules (FR)Apr 8, 2016related by meaning
nancial institution, an insurance company, or a broker-dealer.
Back to Citation
8.
Cerulli Associates, “Retirement Markets 2015.”
Back to Citation
9. The Department initially proposed an amendment to its regulation defining a fiduciary within the meaning of ERISA section 3(21)(A)(ii) and Code section 4975(e)(3)(B) on…
IRCCourt RulingsJan 2, 2020related by meaning
n 72(t) imposes an additional 10% tax on early distributions from a
qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not
attained the age of 59½ when she received the distributions at issue. The IRA
distribution…
IRCCourt RulingsMay 13, 2013related by meaning
r. This occurs where the "taxpayer introduces credible evidence
with respect to * * * [that] factual issue" and the taxpayer has, inter alia, complied with substantiation requirements pursuant to the Code, "maintained all records
required under this title and has cooperated with reasonable requests by the
Secretary for…
IRCCourt RulingsJun 8, 2005related by meaning
cribe Mr. El-Bibany’s
retirement plan, the parties have proceeded on the basis that the
distribution was from an individual retirement plan within the scope of sec. 72(t).
indicated that the early distribution was not subject to tax
under exception 7 (Individual retirement account (IRA)
distributions made to unemployed…
IRCCourt RulingsAug 30, 1999related by meaning
eives 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.
A "qualified retirement pl…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent.
Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
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…