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61. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
62. T.C. Memo. 2017-136 — David D. Pritchard v. Commissioner
    IRCCourt RulingsJul 10, 2017related by meaning
    09). Petitioners concede that none of the exceptions in section 72(t)(2) applies with respect to all or any portion of their retirement distribution.3 On the record before us, we find that petitioners are liable for their taxable year 2008 for the 10-percent additional tax imposed by section 72(t)(1) with respect to th…
63. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
64. Rev. Proc. 2004-15 — Minimum funding standards; waivers; notice. This procedure sets forth guidelines for requesting waivers of the minimum funding standards with respect to define…
    IRCRevenue ProceduresFeb 17, 2004
    …nces, preliminary conferences may be afforded in addition to conferences available under Rev. Proc. 2004-4, 2004-1 I.R.B. 125. SECTION 6. BANKRUPTCY PETITIONS If the applicant or a significant number of controlled group members file a bankruptcy petition after the request for a waiver of the minimum funding standard is…
65. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005related by meaning
    as provided in paragraphs (3) and (4), paragraph (1) shall not apply to any of the following distributions: (A) In general.--Distributions which are-- (i) made on or after the date on which the employee attains age 59 1/2, (ii) made to a beneficiary (or to the estate of the employee) on or after the death (continued...…
66. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
67. T.C. Memo. 2010-200 — Cheryl Elizabeth & Don Edward Hill v. Commissioner
    IRCCourt RulingsSep 13, 2010
    Memo . 1997-331 ; Speer v . Commissioner Memo . 1993- 5 The fol accuracy of appears exce amount of ti (2) the Geor during 2004 . Further petitioner c T .C . Memo . 1996-323 ; Goshorn v . Commissioner , T .C . 1 8 . owing factors further diminish the credibility and etitioner's claim : (1) The number of hours claimed ~…
68. T.C. Summary Opinion 2007-129 — Jeffrey Lee Golian v. Commissioner
    IRCCourt RulingsJul 26, 2007related by meaning
    sioner , T .C . Memo . 2001-34 . We recognize that petitioner received his IRA distribution at a time when he was both a single parent and temporarily unemployed and that he used the distribution for a laudable purpose . Unfortunately for petitioner, we are bound by the lis t of statutory exceptions set forth in sectio…
69. 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…
70. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    IRCCourt RulingsDec 8, 2010related by meaning
    iency on November 24, 2008. Pursuant to section 6503(a) (1), the mailing of the notice of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records - 8 - "so long as the contents thereof may become material in the administration of any internal revenue l…
71. 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…
72. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    IRCCourt RulingsApr 25, 2011related by meaning
    under section 72(t) for an early distribution from a qualified retirement plan in 2005.' 'The 10-percent additional tax applies only to the TSP loans that petitioner failed to repay. Respondent did not assert in (continued...) - 11 - IV. Conclusion In summary, we conclude that (1) petitioner received taxable disability…
73. 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…
74. 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…
75. T.C. Memo. 2006-101 — Eugenie Denise Mitchell v. Commissioner
    IRCCourt RulingsMay 11, 2006related by meaning
    T. C. Memo. 2006-101 CA l STA UNITED STATES TAX COURT . . EUGENIE DENISE MITCHELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7144-04. Filed May ll, 2006. Eugenie Denise Mitchell, pro se. Margaret A. Martin· and Daniel J. Parent, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, …
76. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011related by meaning
    …ess petitioner qualifies for an exception. See sec. 72(t) (1); see also Stipe v. Commissioner, T.C. Memo. 2011-92; Dollander v. Commissioner, T.C. Memo. 2009-187. Petitioner has not alleged that any exception applies, nor has he introduced any evidence that could allow us to conclude that an exception applies. Therefor…
77. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    ermines that there is a deficiency in respect of any tax imposed . . . he is authorized to send notice of such deficiency to the taxpa yer.” I n Scar, the U.S. Court of Appeals for the Ninth Circuit , the court to which appeal in these cases would presumably lie , see § 7482(b)(1)(A) , concluded that , to make such a d…
78. 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…