T.C. Memo. 1997-346
UNITED STATES TAX COURT
WILLIAM L. REESE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18442-95. Filed July 29, 1997.
1. Held: P is taxable on a pension plan
distribution because he failed to roll over that
distribution within the 60-day period prescribed by
sec. 402(a)(5)(C), I.R.C. Held, further, P is liable
for a 10-percent additional tax under sec. 72(t),
I.R.C., on that distribution.
2. Held, further, P is liable for a 10-percent
additional tax under sec. 72(t), I.R.C., on a portion
of a distribution from an individual retirement
account.
3. Held, further, sec. 6651(a)(1), I.R.C.,
addition to tax for failure to file timely return
sustained.
4. Held, further, sec. 6654(a), I.R.C., addition
to tax for failure to pay estimated tax sustained.
William L. Reese, pro se.
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