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1. 89 FR 5624 — Automatic Portability Transaction Regulations
   ERISAProposed Rules (FR)Proposed Jan 29, 2024
   f $7,000 or less 33% 33% = Affected Accounts 5,713,860 5,713,860 × Proportion of Separating Account Holders Subject to Mandatory Distribution 85% 100% = Accounts Subject to Mandatory Distribution 1 4,848,124 5,713,860 Accounts Not Subject to Mandatory Distribution 1 865,736 0 1  These values flow into Table 3. A 2023 r…
2. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
   IRCCourt RulingsMar 10, 2020related by meaning
   sis test. FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose. Sandra M. Conard, pro se. Scott W. Forbord and Mark J. Miller, for respondent. OPINION TORO, Judge: A taxpaye…
3. Treas. Reg. § 1.430(j)-1(f) — Payment of minimum required contributions.
   IRCRegulationsSep 9, 2016
   …pril 15, 2017, and the remaining contribution due on April 15, 2017 is $25,000 minus $17,287, or $7,713.(iii) The interest adjustments in paragraph (ii) of this Example 3 are based on the effective interest rate even if that rate is not determined by the time that the required installment is due. If the plan's effectiv…
4. T.C. Memo. 2021-107 — Gayle Gaston v. Commissioner
   IRCCourt RulingsSep 2, 2021
   …m inant, prim ary or principal objective” of m a king a profit, Wolf v. Com m issioner, 4 F.3d 709, 713 (9th Cir. 1993), aff ’g T.C. Mem o. 1991- 212, and (2) the taxpayer can substantiate the reported expense as an ordinary and necessary business expense, see sec. 183; Dreicer v. Com m issioner, 78 T.C. 642, 645 (1982…
5. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
   IRCCourt RulingsJun 4, 1997
   …ck v. Commissioner , T.C. Memo. 1993-582, affd. per curiam sub nom. Butts v. Commissioner , 49 F.3d 713 (11th Cir. 1995); Butts v. Commissioner , T.C. Memo. 1993-478, affd. per curiam 49 F.3d 713 (11th Cir. 1995) (the Allstate cases). The parties agree that the facts of this case are essentially indistinguishable from …
6. T.C. Memo. 1996-404 — Leonard A. Gross v. Commissioner
   IRCCourt RulingsAug 28, 1996★ strong match
   … different taxes based on two separate returns. S-K - 4 - Liquidating Co. v. Commissioner , 64 T.C. 713, 716 (1975) (involving corporate income tax and withholding tax where the same corporation was the withholding agent); Rowan Cotton Mills Co. v. Commissioner
7. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsJan 17, 2024related by meaning
   Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
8. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
   IRCCourt RulingsDec 2, 2010related by meaning
   wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
9. 80 FR 54374 — Determination of Minimum Required Pension Contributions
   IRCFinal Rules (FR)Sep 9, 2015
   e remaining contribution due on April 15, 2017 is $25,000 minus $17,287, or $7,713. (iii) The interest adjustments in paragraph (ii) of this Example 3 are based on the effective interest rate even if that rate is not determined by the time that the required installment is due. If the plan's effective interest rate for …
10. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
11. T.D. 9732 — These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also cont…
    IRCTreasury DecisionsSep 28, 2015
    …pril 15, 2017, and the remaining contribution due on April 15, 2017 is $25,000 minus $17,287, or $7,713. (iii) The interest adjustments in paragraph (ii) of this Example 3 are based on the effective interest rate even if that rate is not determined by the time that the required installment is due. If the plan’s effecti…
12. 105 T.C. No. 29 — John U. & Sylvia Fazi v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …tributions were made to an unqualified trust and not at the time of distribution." Fazi I, supra at 713. Respondent conceded in Fazi I that the merged amount would be taxable in 1986, rather than 1987. Petitioners, in Fazi I,
13. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
14. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    distribution qualified for tax-free rollover treatment under section 402(a)(5); Brown v. Commissioner , T.C. Memo. 1995-93 (same); cf. supra with T.C. Memo. 1993-561. - 13 - 10 It would appear that such stipulation would also affect the amount of the excise tax under sec. 4980A. We leave this matter to the parties as p…
15. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    B) simply does not apply here because we do not have a lump sum distribution within subparagraph (A). 2. 10-Percent Additional Tax Under Section 72(t) Petitioner has disputed the Commissioner’s imposition of a 10-percent addition to tax on the lump sum distribution. In the assignments of error in the petition to this C…
16. 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,…
17. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
18. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    See Parker v. Commissioner, T.C. Memo. 2012-66, 103 T.C.M. (CCH) 1321, 1323 (finding section 6201(d) inapplicable where the tax- (continued...) - 10 - [*10] Petitioner has not satisfied his burden of proof. He failed in his petition to assign error to any of respondent's determinations, asserting instead that he had no…
19. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ities. Classification of the transaction as a prohibited transaction under section 408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is subject to a 10-percent additional tax. See secs. 72(t), 408(e) (2) (]B). In cases where the Service att…
20. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    ficiency for the years in issue. Respondent determined that petitioner was liable for additional taxes of $499 and $5,215 for early distributions from her IRAs for 1999 and 2000, respectively. Respondent also determined that petitioner was liable for additions to tax under sections 6651(a)(1) and 6654(a), as set out ab…