Legal Opinion

Arnold v. Commissioner

United States Tax Court

Decided September 28, 1998No. Tax Ct. Dkt. No. 16855-97Published

In December 1989, following P's retirement, P began receiving annual distributions from his individual retirement account (IRA). At that time, P was 55 years old. The distributions were intended to constitute a series of substantially equal periodic payments within the purview of sec. 72(t)(2)(A)(iv), I.R.C., so as to avoid P's having to pay the 10-percent tax pursuant to sec. 72(t)(1), I.R.C.

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In December 1989, following P's retirement, P began receiving annual distributions from his individual retirement account (IRA). At that time, P was 55 years old. The distributions were intended to constitute a series of substantially equal periodic payments within the purview of sec. 72(t)(2)(A)(iv), I.R.C., so as to avoid P's having to pay the 10-percent tax pursuant to sec. 72(t)(1), I.R.C. In November 1993, after five distributions of $ 44,000 each had been made, and when P attained age 59-1/2, P received $ 6,776 from his IRA. In the notice of deficiency, R determined that the November…

1Opinion of the Court

ROBERT C. AND NANCY L. ARNOLD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Arnold v. Commissioner

Tax Ct. Dkt. No. 16855-97

United States Tax Court

111 T.C. 250; 1998 U.S. Tax Ct. LEXIS 48; 111 T.C. No. 12;

September 28, 1998, Filed

In December 1989, following P's retirement, P began receiving annual distributions from his individual retirement account (IRA). At that time, P was 55 years old. The distributions were intended to constitute a series of substantially equal periodic payments within the purview of sec. 72(t)(2)(A)(iv), I.R.C., so as to avoid P's having to pay the…

2Cases cited3 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Dwyer v. CommissionerUnited States Tax Court · 1996
  3. Arnold v. CommissionerUnited States Tax Court · 1998

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