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61. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    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…
62. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
63. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    tever source derived, including (but not limited to) the following items: ******* (11) Pensions; SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
64. T.C. Summary Opinion 2004-135 — Charlotte Marie Scott v. Commissioner
    IRCCourt RulingsSep 30, 2004related by meaning
    etitioner did not “roll over” her distributions pursuant to section 408(d)(3). - 6 - Therefore, in order for petitioner to prevail, she must show that the distributions fall under one of the exceptions under section 72(t)(2). With respect to section 72(t), this Court has repeatedly held that it is bound by the list of …
65. 76 T.C. 861; 2 Employee Benefits Cas. (BNA) 1450 — Estate of Perl v. Commissioner
    IRCCourt RulingsMay 27, 1981related by meaning
    nder either a trusteed pension plan or a retirement annuity contract. Petitioner none too clearly seems to adopt a contrary posture as to both issues. At the outset, we note that both the petitioner and respondent treat the T.I.A.A. and C.R.E.F. annuity contracts as being entirely separate from the life insurance and d…
66. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
67. 40 T.C. 882 — New York Post Corp. v. Commissioner
    IRCCourt RulingsAug 26, 1963related by meaning
    ly” or “primarily,” petitioner’s plan involved neither “solely” nor “primarily” a dismissal wage so as to remove it from the operation of section 404. Both versions of the regulations recognize that there are certain types of payments to employees that are not to be regarded as deferred compensation within the meaning …
68. U.S. Tax Court — Michael K. Billups v. Commissioner
    IRCCourt RulingsJun 1, 2009related by meaning
    account of the employee's disability ; (4) as part of a serie s e for life ; (5) to a employee after separation from service after attainment of ag A substantially equal periodic payments m 55 ; (6) as dividends paid with, respect to corporate stoc k described in section 404(k) ; (7) to an employee for medica l or (8)…