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81. T.C. Summary Opinion 2016-52 — Bruce W. Peterson & Lisa A. Peterson v. Commissioner
    IRCCourt RulingsSep 1, 2016
    …ot the Commissioner, prescribes the tax laws[.]"); see also Zimmerman v. Commissioner, 71 T.C. 367, 371 (1978), aff'd without published opinion, 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner, 59 T.C. 456, 458 (1972). - 10 - under section 72(t).° Petitioner was 60 years old when he received the Forethought distrib…
82. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020related by meaning
    little more than guesswork and failed to satisfy the strict substantiation requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section 274(d). Cons…
83. T.C. Summary Opinion 2017-64 — Wilfred Omoloh v. Commissioner
    IRCCourt RulingsAug 16, 2017related by meaning
    en of proving that those determinations are erroneous.4 See Rule 142(a); Welch v. Helvering, 290 U.S. I11, 115 (1933). I. Section 72(t) Additional Tax Section 72(t)(1) imposes an additional tax on an early distribution from a qualified retirement plan equal to 10% of the portion of the amount that is includable in gros…
84. T.C. Memo. 1997-15 — Mark J. Vorwald v. Commissioner
    IRCCourt RulingsJan 8, 1997
    … Trust Co. v. Commissioner , 279 U.S. 716, 729 - 4 - (1929); see Poczatek v. Commissioner , 71 T.C. 371, 378 (1978). We note that had petitioner voluntarily assigned his interest in the IRA to his former spouse in connection with the debt that he owed to her, the assignment would be deemed a distribution. Sec. 1.408-4(…