Arnold v. Commissioner
United States Tax Court
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
- Welch v. HelveringSupreme Court of the United States · 1933
- Dwyer v. CommissionerUnited States Tax Court · 1996
- Arnold v. CommissionerUnited States Tax Court · 1998