72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner IRCCourt RulingsJun 11, 1979related by meaning
n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …
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 RulingsJan 14, 2013related by meaning
sonable compensation and therefore not deductible under
section 162 (and thereby section 404), the 10% section 4972 excise tax applies to
that extent. V. Section 6651(a)(1) and (2) Additions to Tax
Respondent contends that the corporation is liable for section 6651(a)(1)
failure to file additions to tax of $10,050.95 a…
71 T.C. 1011 — Orthopedics International, Ltd., P.S. v. Commissioner IRCCourt RulingsMar 19, 1979related by meaning
section 404(a)(7) and section 1.404(a)-13, Income Tax Regs., is reasonable and wé refuse to hold it invalid.
Decision will be entered under Rule 155. Petitioner has also agreed to an adjustment to its taxable income made by respondent for forfeitures not properly offset by petitioner against its allowable pension plan…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
IRCCourt RulingsMay 19, 2011related by meaning
An IRA is a qualified
retirement plan to which section 72(t) (1) applies. See secs.
408(a), 4974(c) (4). Respondent introduced evidence at trial from third-party payers which established that petitioner received
gross distributions of $183,007 from an IRA and that $9,166 of
that amount was taxable to her. Petitioner h…
IRCCourt RulingsJul 13, 2010related by meaning
.a distribution
of $6,277 from a qualified retirement . plan during~the'2001 tax
year and that .she was under the age of 59-l/2 , at "the time of the distribution . . At trial Ms . O'Boyle presented no evidence that
she qualified for any of the . exceptions in section 72(t)(2) .
Accordingly ; we hold that Ms .-O'Boyle…
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
IRCCourt RulingsDec 18, 2012related by meaning
, petitioners contend, because they contributed at least that amount in
each of those years to qualified plans and claimed corresponding deductions on their joint returns for those years. As petitioners see it, they may deduct any
amount claimed on those returns as a retirement plan contribution because the
notices of …
Notice 2026-34 — 2026 Cumulative List of Changes in Plan Qualification Requirements for Defined Benefit Qualified Pre-approved Plans IRCNoticesJun 1, 2026
…026-22 I.R.B. 2026-22 1515
Treasury Decisions:
Article Issue Link Page
10042 2026-03 I.R.B. 2026-03 320
10041 2026-04 I.R.B. 2026-04 360
10039 2026-05 I.R.B. 2026-05 403
10040 2026-05 I.R.B. 2026-05 416
10043 2026-15 I.R.B. 2026-15 793
10044 2026-18 I.R.B. 2026-18 840
Treasury Decisions:—Continued
Article Issue Link Pa…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026
…026-24 I.R.B. 2026-24 1570
Treasury Decisions:
Article Issue Link Page
10042 2026-03 I.R.B. 2026-03 320
10041 2026-04 I.R.B. 2026-04 360
10039 2026-05 I.R.B. 2026-05 403
10040 2026-05 I.R.B. 2026-05 416
Treasury Decisions:—Continued
Article Issue Link Page
10043 2026-15 I.R.B. 2026-15 793
10044 2026-18 I.R.B. 2026-18 8…
IRCCourt RulingsSep 30, 2003related by meaning
ance with its substance.”
Neonatology Associates, P.A. v. Commissioner
, 299 F.3d 221, 230
n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is
free to organize his affairs as he chooses, nevertheless, once
having done so, he must accept the tax co…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026
…2026-19 I.R.B. 2026-19 897
Treasury Decisions:
Article Issue Link Page
10042 2026-03 I.R.B. 2026-03 320
10041 2026-04 I.R.B. 2026-04 360
10039 2026-05 I.R.B. 2026-05 403
10040 2026-05 I.R.B. 2026-05 416
10043 2026-15 I.R.B. 2026-15 793
10044 2026-18 I.R.B. 2026-18 840
10045 2026-21 I.R.B. 2026-21 1491
10047 2026-21 I.R…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026
…026-22 I.R.B. 2026-22 1515
Treasury Decisions:
Article Issue Link Page
10042 2026-03 I.R.B. 2026-03 320
10041 2026-04 I.R.B. 2026-04 360
10039 2026-05 I.R.B. 2026-05 403
10040 2026-05 I.R.B. 2026-05 416
10043 2026-15 I.R.B. 2026-15 793
10044 2026-18 I.R.B. 2026-18 840
Treasury Decisions:—Continued
Article Issue Link Pa…
IRCCourt RulingsAug 8, 2019related by meaning
he foregoing principles in mind, we turn to section 72(t)(2)(F) and
begin with its title: "Distributions from certain plans for first home purchases." Although statutory titles and section headings do not define a statute's meaning
and are not generally relied on at the expense of the statutory text itself, such titles…
IRCPrivate Letter RulingsAug 27, 1999
… a plan or policy ... which provides for vacations with pay
to qualified employees.
See 1958-3 C.B. 320. Congress repeatedly extended the delay in application of
year taxpayer accrued vacation pay on a monthly basis. The employment contracts
provided that "[a]ll mine workers with a record of twelve (12) months continuo…
IRCCourt RulingsJan 30, 2007related by meaning
s were attributable to
disability, or that the distributions otherwise qualify for an
exception to the 10-percent additional tax. In fact, petitioners state on brief that "Petitioners do understand that petitioners
have to pay 10% penalty tax on the amount stated above * * * This
is consistent with IRC section 72(t) (1…
IRCPrivate Letter RulingsDec 1, 2006
…subject of an incomplete Inter vivos transfer." In United States
v. Estate of Grace
, 395 U.S. 316, 320, 89 S. Ct. 1730, 1733, 23 L. Ed. 2 d 332
(1969) , the Court noted:
TAM - 142156-05
15
The general purpose of the statute was to include in a decedent's gross
estate transfers that are essentially testamentary; i. e.,…
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…