Accuracy Related Penalty

Harriss v. Commissioner (T.C. Memo. 2021-31)

On March 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Harriss v. Commissioner (T.C. Memo. 2021-31). The primary issues presented in Harriss were whether the notices of deficiency issued to the petitioners were valid and whether the petitioner is liable under IRC § 72(t) for the early withdrawal penalty. Shenanigans The petitioner was paid, on average, $150,000 in 2012, 2013, and 2014.  Forms 1099 were issued.  Taxes were withheld. In

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Early Withdrawal Penalty

Grajales v. Commissioner (156 T.C. No. 3)

On January 25, 2021, the Tax Court issued its opinion in Grajales v. Commissioner, 156 T.C. No. 3. The underlying issue presented in Grajales was whether prior written supervisory approval under IRC § 6751(b)(1) was required to assert the 10% IRC § 72(t) “exaction” for early distributions from a qualified retirement plan. Labels are for Cans Abraham Lincoln is credited for saying “How many legs does a dog have if you call his tail a

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Harriss v. Commissioner (T.C. Memo. 2021-31)

On March 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Harriss v. Commissioner (T.C. Memo. 2021-31). The primary issues presented in Harriss were whether the notices of deficiency issued to the petitioners were valid and whether the petitioner is liable under IRC § 72(t) for

Read More »

Grajales v. Commissioner (156 T.C. No. 3)

On January 25, 2021, the Tax Court issued its opinion in Grajales v. Commissioner, 156 T.C. No. 3. The underlying issue presented in Grajales was whether prior written supervisory approval under IRC § 6751(b)(1) was required to assert the 10% IRC § 72(t) “exaction” for early distributions from a qualified

Read More »