Bohner v. Commissioner
United States Tax Court
While P worked for the Federal Government, he participated in the Civil Service Retirement System (CSRS). After P retired, he received a letter explaining that he could elect to increase his CSRS retirement annuity by remitting a fixed sum. P remitted the funds to CSRS. Because P did not have sufficient funds in his bank account, he borrowed a portion of the fixed sum.
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While P worked for the Federal Government, he participated in the Civil Service Retirement System (CSRS). After P retired, he received a letter explaining that he could elect to increase his CSRS retirement annuity by remitting a fixed sum. P remitted the funds to CSRS. Because P did not have sufficient funds in his bank account, he borrowed a portion of the fixed sum. P paid off the loan and replenished his bank account by making withdrawals from his traditional individual retirement account (IRA). P did not report any of the amounts he withdrew from his IRA as taxable income. P contends…
1Opinion of the Court
Kerrigan, Judge:
Respondent determined a deficiency of $4,590 with respect to petitioner’s Federal income tax for tax year 2010.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The sole issue for consideration is whether a tax-free rollover occurred when petitioner withdrew funds from his traditional individual retirement account (IRA) to cover a deposit of the same amount to the Civil Service Retirement System (CSRS).
FINDINGS OF FACT
Some facts have…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Carolyn J. Guilzon, Individually and as of the Estate of Edward J. Guilzon, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993
- Arnold v. CommissionerUnited States Tax Court · 1998
- Schoof v. CommissionerUnited States Tax Court · 1998
- Shimota v. United StatesUnited States Court of Claims · 1990
7 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
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- Dennis E. Bohner v. CommissionerUnited States Tax Court · 2014