Legal Opinion

Campbell v. Commissioner

United States Tax Court

Decided February 18, 1997No. Docket No. 12931-95Published

P was a State employee. In October 1989, P elected to transfer from the State Retirement System to the State Pension System effective November 1989. As a consequence, P received a Transfer Refund in 1989 consisting principally of previously taxed contributions and taxable earnings. Shortly thereafter, P deposited approximately one-half of the taxable portion into an IRA with Loyola.

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P was a State employee. In October 1989, P elected to transfer from the State Retirement System to the State Pension System effective November 1989. As a consequence, P received a Transfer Refund in 1989 consisting principally of previously taxed contributions and taxable earnings. Shortly thereafter, P deposited approximately one-half of the taxable portion into an IRA with Loyola. P included the entire taxable portion of the Transfer Refund in income on an amended tax return for 1989. See Dorsey v. Commissioner, T.C. Memo. 1995-97. In April 1991, P closed his Loyola IRA. On a 1991 tax…

1Opinion of the Court

GEORGE AND ELAM CAMPBELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Campbell v. Commissioner

Docket No. 12931-95

United States Tax Court

108 T.C. 54; 1997 U.S. Tax Ct. LEXIS 5; 108 T.C. No. 5; 20 Employee Benefits Cas. (BNA) 2612;

February 18, 1997, Filed

Decision will be entered under Rule 155.

P was a State employee. In October 1989, P elected to transfer from the State Retirement System to the State Pension System effective November 1989. As a consequence, P received a Transfer Refund in 1989 consisting principally of previously taxed contributions and taxable earnings. Shortly…

2Cases cited16 opinions

  1. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
  2. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  3. Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
  4. Pallottini v. CommissionerUnited States Tax Court · 1988
  5. Huntsberry v. CommissionerUnited States Tax Court · 1984

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