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61. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
62. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    income of $198,111. RA Landadio calculated an income tax of $49,507 and also a section 72(t) tax of $20,811, which he assumed petitioner owed because he considered the pension distribution to be an early distribution from a qualified retirement plan. RA Landadio summed those two amounts to arrive at a deficiency in ta…
63. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    nd contribution, made during December 1986, would be deductible in 1986, because that contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986. Accordingly, petitioner argues, the regulation contradicts the plain language of section 419 and is invalid. Petiti…
64. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985related by meaning
    Panuthos, Special Trial Judge: This case was heard pursuant to the provisions of section 7456(d) of the Code. Respondent determined a deficiency of $474.10 in petitioner’s 1981 Federal income tax. The issue for decision is whether petitioner is entitled to a deduction of $1,500 for a contribution to an Individual Retir…
65. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
66. T.C. Summary Opinion 2004-146 — Jack A. & Theresa Y. Smith v. Commissioner
    IRCCourt RulingsOct 21, 2004related by meaning
    T.C. Summary Opinion 2004-146 UNITED STATES TAX COURT JACK A. AND THERESA Y. SMITH, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11507-02S. Filed October 21, 2004. Randy P. Zinna , for petitioners. Brenda Fitzgerald , for respondent. PAJAK, Special Trial Judge : This case was heard pursuant t…
67. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
68. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    3,155 710 442 12/31/84 4,025 .906 322 12/31/85 4,935 888 99 Respondent also determined a deficiency in second-tier tax under sec. 4975(b) of $101,843. Melvin C. Dace Docket No. 39553-87 Sec. 4975(a) first-tier tax Additions to tax TYE deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) 12/31/80 $1,936 $436 $484 12/31/81 4,926 1…
69. 35 T.C. 1217 — Searl v. Commissioner
    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…
70. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…