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61. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    ble person could have concluded that the filing of an excise tax return was not required because the transfer was not a prohibited transaction, or, if it was, that it had been corrected. Andrew I. Panken and Robert A. DeVellis , for petitioner. Catherine R. Chastanet , for respondent. MEMORANDUM OPINION LARO, Judge : T…
62. 89 FR 65779 — Prohibited Transaction Class Exemption 84-14 for Transactions Determined by Independent Qualified Professional Asset Managers (the QPAM Exemption); Correction
    ERISAFinal Rules (FR)Aug 13, 2024
    … fiscal year ending no later than December 31, 2027, substitute $118,912,000 for $85,000,000 and $1,694,000 for $1,000,000.
63. 100 T.C. 521; 100 T.C. No. 34 — Karem v. Commissioner
    IRCCourt RulingsJun 14, 1993related by meaning
    e taxpayer in Darby was the distributee of the entire distribution and therefore not entitled to exclude any part of the distribution from his income. Here we have held that there was no QDRO directing payment from the plan to Barbara. We conclude that, in accordance with section 402(e)(4)(G) and with Ablamis and Darby…
64. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997
    …rn, petitioner reported wage income attributable to his employment at Strahman in the amount of $20,694.16. Respondent determined that petitioner was liable for unreported wage income in the amount of $23.20. The parties agree that the amount in question relates to the cost of the portion of employer-provided group ter…
65. T.C. Memo. 2010-262 — Hal Hollingsworth v. Commissioner
    IRCCourt RulingsDec 2, 2010
    …ocument from the foundation "Also related to his 401(k) account withdrawals, petitioner included $1,694 of sec. 72(t) additional tax "on IRAs, other qualified retirement plans, etc." - 8 - which was identical to the first except that the line for the donor which was previously blank now contained petitioner's name. Bot…
66. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995related by meaning
    -2503 at 95-2504, 95-1 USTC par. 50,280 (D. Md. 1995); see also Conway v. United States , supra ; cf. Wheeler v. Commissioner , T.C. Memo. 1993-561. 6 We observe that the definition of "qualified total distribution" set forth in section 402(a)(5)(E)(i)(II) incorporates the definition of "lump sum distribution" set fort…
67. 144 T.C. No. 15 — Whistleblower 21276-13W v. Commissioner
    IRCCourt RulingsJun 2, 2015
    …he government's actions against * * * [the Targeted Business] that led to the collection of $74,131,694.42. The IRS was ikivolved in the pursuit of the Targeted Business from the beginning of the investigation. At the partial trial before this Court, the IRS special agent involved in thb investigation of the Targeted B…
68. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    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…
69. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …0 85,000 - Motorboat 8,000 8,000 - Auto 17,000 20,000 [sic] Art, etc. 40,000 20,000 20,000 Totals 1,694,322 [sic] 1,010,771 683,551 With an exception for the four IRA's, the 401(k) plan, and the stock of the six listed corporations, the parties stipulated on May 16, 1995, to the accuracy of the preceding statement. 23 …
70. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related 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 Practice and Procedure. T.C. Memo. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTE…
71. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …3 Frank A. Pettisani 1 1983 270,425 and Lucille M. Pettisani 1984 606,481 1985 1,014,702 1986 1,304,694 1987 293,682 1 In this case, respondent determined substantial deficiencies and additions to tax arising from petitioners' activities, including investments in various partnerships and S corporations. The only portio…
72. 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…
73. T.C. Memo. 1996-337 — Parker-Hannifin Corporation v. Commissioner
    IRCCourt RulingsJul 24, 1996
    … of the VEBA Trust: Year Ended Amount 1 June 30, 1988 $ 529,543 June 30, 1989 574,034 June 30, 1990 694,697 June 30, 1991 739,874 June 30, 1992 871,953 June 30, 1993 926,162 June 30, 1994 1,158,574 1 Because the VEBA Trust reimbursed Provident for these payments, there is a slight timing difference resulting from these…
74. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    on in Bullard, was — for the reasons stated earlier — not a lump sum distribution and thus was not eligible for lump sum averaging in the first place. The Commissioner’s determination of additional tax under section 72(t) is sustained. Decision will be entered for respondent. Except as otherwise indicated, all section …
75. 37 T.C. 7 — Barbourville Brick Co. v. Commissioner
    IRCCourt RulingsOct 9, 1961related by meaning
    e distribution. Although section 816 of the 1954 Code rather than section 115 of the 1939 Code is applicable here, the relevant language is identical. The dividend issue was raised expressly by respondent for the first time at the trial by the statement that “the amounts involved in this case are * * * a preferential o…
76. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    4). We do not find Rev. Rul. 69-647 intrinsically persuasive, and we agree with the Claims Court that it is distinguishable on its facts in any event. Of course, a distribution upon plan termination may be a ''qualifying rollover distribution” under sec. 402(a)(5)(D), and be rolled over into another qualifying plan. Se…
77. 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…
78. 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. …
79. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. All monetary amounts are rounded to the nearest dollar. 2Petitioners conceded that they were not entitled to exclude from gross income rental income of $4,920 they received in 2007. - 3 - [*3] to deduct a net operating loss (…
80. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …