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61. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ort the 10-percent additional tax, believing that he qualified for the disability exception. Although petitioner failed to qualify under the technical provisions of the Internal Revenue Code and the regulations, we - 13 - do not believe petitioner acted unreasonably or intentionally disregarded the rules and regulation…
62. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    … "supposed to make any other assessments [of tax] for that year." The examination of the Goldbergs' 2004 tax year could yield deficiencies and additions to tax, which would in turn lead to assessments of tax. If the IRS accepted Goldberg's pending offer-in-compromise while the 2004 examination was still taking place, t…
63. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    to the additional tax under section 72(t) and distinguished Larotonda and Murillo on the ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is equally true of the distribution here. - 5 - To reflect the foregoing, An appropriate order of dismissal a…
64. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
65. T.C. Memo. 2009-38 — Nancy Garza-Martinez v. Commissioner
    IRCCourt RulingsMar 23, 2009related by meaning
    …intains that she should-no,t be subject to the 10-percent additional tax under section 72(t)(1) for 2004 because, as noted supra , she received those additiona l 'Sec . 72(t)(4) provides in pertinent part : (4) Change in substantially equal payments .-- (A) In general .--If-- (i) paragraph (1) does not apply to a distr…
66. T.C. Summary Opinion 2007-180 — Suzanne E. Barrera, a.k.a. Suzanne E. Battle v. Commissioner
    IRCCourt RulingsOct 24, 2007
    …eturn. See, e.g., Hopkins v. Commissioner , 121 T.C. 73, 88-89 (2003); Knorr v. Commissioner , T.C. Memo. 2004-212; Morello v. Commissioner , T.C. Memo. 2004-181; Keitz v. Commissioner , T.C. Memo. 2004-74; Ogonoski v. - 35 - Commissioner , T.C. Memo. 2004-52; Wiest v. Commissioner , T.C. Memo. 2003-91; see also Rev. P…
67. 132 T.C. No. 15 — Gregory T. & Kim D. Benz v. Commissioner
    IRCCourt RulingsMay 11, 2009
    …ry 1 5 each year for a period based on petitioner wife's life expectancy . On or-before January 15, 2004, petitioner wife received a $102,311 .50 distribution from her IRA in accordance with-her election to receive a series of-substantially equal periodic payments . During 2004 petitioner wife received two additional d…
68. T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover …
    IRCTreasury DecisionsMar 23, 2009related by meaning
    on 414(w) for the entire plan year (or the portion of the plan year that the eligible NHCEs and eligible HCEs are eligible employees under the plan)). Qualified nonelective contributions and qualified matching contributions taken into account under §1.401(k)-2(a)(6) of this Chapter or qualified nonelective contribution…
69. Rev. Proc. 2005-25 — Fair market value; distributions; qualified retirement plans. This procedure provides guidance, including examples, of how fair market value may be determined …
    IRCRevenue ProceduresApr 25, 2005
    …evenue procedure applies to distributions, sales, and other transfers made on or after February 13, 2004, to permanent benefits within the meaning of § 1.79-0 provided on or after February 13, 2004, and to non-exempt employees’ trusts under § 402(b) for periods on or after February 13, 2004. However, for periods before…