Doing v. Commissioner
United States Tax Court
In 1964, petitioner established a self-employment profit-sharing retirement plan with an investment fund held under a bank custodial account. In 1966, he decided to change his investment medium from this initial fund to another fund. Petitioner made an application for a self-employment profit-sharing retirement plan with a new bank custodian to invest in the second fund.
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In 1964, petitioner established a self-employment profit-sharing retirement plan with an investment fund held under a bank custodial account. In 1966, he decided to change his investment medium from this initial fund to another fund. Petitioner made an application for a self-employment profit-sharing retirement plan with a new bank custodian to invest in the second fund. He then requested the first custodian to liquidate the shares in the initial fund and forward the proceeds directly to the second fund under the new custodial account. The first custodian, instead, sent the proceeds by check…
1Opinion of the Court
Hoyt, Judge:
The Commissioner determined deficiencies in the petitioners’ Federal income tax in the amount of $519.26 for the calendar year 1966 and $98 for the calendar year 1967. The issues presented are: (1) Whether petitioner Keith L. Doing received a premature distribution in 1966 from a self-employment retirement plan within the meaning of section 72 (m) (5) (A) (i)1 so as to render the petitioners liable for the tax imposed by section 72(m) (5) (C); and if so, (2) whether petitioners’ deduction for contributions in 1967 to a self-employment retirement plan is prohibited by the…
2Cases cited7 opinions
- Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
- Girard Trust Co. v. United StatesSupreme Court of the United States · 1926
- United States v. Rhode Island Hospital Trust CompanyCourt of Appeals for the First Circuit · 1966
- Fuchs v. CommissionerUnited States Tax Court · 1966
- National Metropolitan Bank v. United StatesUnited States Court of Claims · 1950
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Tufts v. CommissionerUnited States Tax Court · 1978
- Ziegler v. CommissionerUnited States Tax Court · 1978
- Doing v. CommissionerUnited States Tax Court · 1972
- Gunther v. CommissionerUnited States Tax Court · 1989
- Gunther v. CommissionerUnited States Tax Court · 1989
2 more not listed; retrieve them via the Exa API.