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61. T.C. Memo. 1996-378 — Gaylord W. Greenlee v. Commissioner
    IRCCourt RulingsAug 15, 1996related by meaning
    c. Year 6651(a)(1) 1985 $ 813 1986 1,123 1987 1,403 1988 1,529 1989 1,581 1990 1,539 Then, in her reply brief, she conceded that the correct additions to tax are as stated in the text. The primary issue for decision is whether petitioner engaged in a prohibited transaction so as to be subject to the first-tier excise t…
62. 40 T.C. 7 — Heard v. Commissioner
    IRCCourt RulingsApr 10, 1963
    …irement Act, which was enacted in 1920, that such was the intent. The Revenue Act of 1918, 40 Stat. 1057, then in effect, defined gross income as “gain or profits and income derived from any source whatever.” Sec. 213(a). The courts have construed the taxing acts as applying to all gains except those specifically exemp…
63. 78 T.C. 930; 78 T.C. No. 66 — Hauser v. Comm'r
    IRCCourt RulingsJun 9, 1982
    … prohibition of section 219(b). Johnson v. Commissioner, 661 F.2d 53 (5th Cir. 1981), affg. 74 T.C. 1057 (1980). Also, the rationale adopted by the Court of Appeals for the Seventh Circuit in Foulkes v. Commissioner, 638 F.2d 1105 (7th Cir. 1981), revg. a Memorandum Opinion of this Court, which holds that a taxpayer is…
64. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
65. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985
    … months of 1981. Chapman v. Commissioner, 77 T.C. 477, 480 (1981); Johnson v. Commissioner, 74 T.C. 1057, 1060 (1980), affd. 661 F.2d 53 (5th Cir. 1981). Finally, section 4973 imposes an excise tax of 6 percent on "excess contributions” made to an IRA during the taxable year. Section 4973(b) defines "excess contributio…
66. 78 T.C. 86; 78 T.C. No. 6 — Horvath v. Commissioner
    IRCCourt RulingsJan 20, 1982
    …mmissioner, 77 T.C. 477 (1981); Johnson v. Commissioner, 661 F.2d 53 (5th Cir. 1981), affg. 74 T.C. 1057 (1980). As previously noted, respondent included the interest income credited to the IRA during 1976 in petitioners’ taxable income, based upon his disallowance of the deduction for the contribution to the IRA.
67. 29 C.F.R. § 4907.112-4907.129 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
68. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984
    …lover that is attributable to the nonexempt life of the trust. See Johnson v. Commissioner, 74 T.C. 1057, 1059-1061 (1980), affd. 661 F.2d 53 (5th Cir. 1981), for a more detailed explanation of how such calculations are to be made, both for the year in which the contribution was made (1978), and for the subsequent year…
69. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
70. T.C. Memo. 2000-219 — Stephen R. Jones v. Commissioner
    IRCCourt RulingsJul 20, 2000related by meaning
    gross income by the payee or distributee, as the case may be, in the manner provided under section 72.” Petitioner contends that by endorsing his IRA distribution check to his spouse, whom he was divorcing, he complied with an exception to section 408(d)(1) contained in section 408(d)(6), which provides: (6) TRANSFER …