§1303

DIST. Eldon R. & Susan M. Kenseth, Petitioner 114 T.C. No. 26 · 2000

Estate of Gadlow is similarly distinguishable from the case at hand.

Kenseth v. Commissioner 114 T.C. 399 · 2000

to follow a wrong path decades ago. Respectfully, I dissent. Parr, Wells, Colvin, and Beghe, JJ., agree with this dissenting opinion. The statute referred to in O’Brien v. Commissioner, 38 T.C. 707, 710 (1962), affd. 319 F.2d 532 (3d Cir. 1963), is sec. 1303, I.R.C. 1954, which provided a “cap” on taxation of backpay awards, calculated by “spreading back” the award over the years to which the awarded amounts were attributable. We held that the gross award was to be spread back, unreduced by the

George C. Huff, Petitioner and The Government of the United States Virgin Islands, Intervenor, Petitioners 138 T.C. No. 11 · 2012

Article 8 ofNASCO's articles oforganikation provides: "No member ofthe Company shall be liable for the debts and obligations ofthe Company under Section 1303, Subsection (c) oftl e Uniform Limited Liability Act." During each o the years involved NASCO had morethan 10 nembers and at least 1 ofits mem ers was neither an individual, a C corporation, nor an estate 4Respondent asserts alternate positions in the notice ofdeficiency.

Huff v. Commissioner 138 T.C. 258 · 2012

Article 8 of NASCO’s articles of organization provides: “No member of the Company shall be liable for the debts and obligations of the Company under Section 1303, Subsection (c) of the Uniform Limited Liability Act.” During each of the years involved NASCO had more than 10 members and at least 1 of its members was neither an individual, a C corporation, nor an estate of a deceased person.

Douglass H. & Suzanne M. Bartley, Petitioner T.C. Memo. 1998-322 · 1998

during the 4 taxable years commencing upon attaining the age of 21 and ending with the computation year would be eligible for income averaging. Former sec. 1303(c)(2)(A) (Tax Reform Act of 1986, Pub. L. 99-514, sec. 141(a), 100 Stat. 2117, repealed sec. 1303, applicable to tax years beginning after Dec. 31, 1986); see Baldwin v. Commissioner, 84 T.C. 859, 869 (1985). In addition, if a taxpayer fails to roll over distributed retirement funds within 60 days, and the distribution is made before th

Jolitz v. Commissioner 73 T.C. 732 · 1980

Heidel v. Commissioner 56 T.C. 95 · 1971

Robillard v. Commissioner 35 T.C. 896 · 1961

Baldwin v. Commissioner 84 T.C. 859 · 1985

Sharvy v. Commissioner 67 T.C. 630 · 1977

More v. Commissioner 66 T.C. 27 · 1976

Felman v. Commissioner 49 T.C. 599 · 1968

Estate of Gadlow v. Commissioner 50 T.C. 975 · 1968

O'Brien v. Commissioner 38 T.C. 707 · 1962

St. Jude Medical, Inc. v. Commissioner 97 T.C. 457 · 1991

Ann Jackson Family Foundation v. Commissioner 97 T.C. 534 · 1991

Graves v. Commissioner 88 T.C. 28 · 1987

Frost v. Commissioner 61 T.C. 488 · 1974

Mariani v. Commissioner 54 T.C. 135 · 1970

United States v. Tann 577 F.3d 533 · Cir.

Liberty University v. Timothy Geithner · Cir.

Burstein v. Retirement Account Plan for Employees of Allegheny Health Education & Research Foundation 334 F.3d 365 · Cir.

Pension Benefit Guaranty Corp. v. Wilson N. Jones Memorial Hospital 374 F.3d 362 · Cir.

Liberty University v. Timothy Geithner 671 F.3d 391 · Cir.

Liberty University v. Timothy Geithner · Cir.

William H. Burstein, M.D. v. Retirement Account Plan For Employees Of Allegheny Health Education And Research Foundation 334 F.3d 365 · Cir.

26 Citing Cases