Tax Court In Brief | Patrinicola v. Comm’r | Taxability Of Pension Distributions

Patrinicola v. Comm’r, T.C. Memo. 2023-16| February 14, 2023 | Goeke, J. | Dkt. No. 498-19

Summary: In this opinion, the Tax Court considered whether a deficiency was appropriate for Tony and Barbara Patrinicola’s 2016 tax year. The IRS determined that they had received unreported taxable pension distributions of $6,750. For the 2016 tax year, General Electric Pension Trust (General Electric) issued Form 1099–R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc., to Mr. Patrinicola reporting payment of $22,773 in taxable pension distributions, and State Street Retiree Services (State Street) issued three Forms 1099–R that reported payments of $252, $4,627, and $3,412 in taxable pension distributions to Mr. Patrinicola. According to these Forms 1099–R, Mr. Patrinicola received total pension distributions of $31,064. Ms. Patrinicola received a Form 1099–R that reported that she received $2,592 in nontaxable retirement income. On their 2016 tax return, the Patrinicolas reported gross income from pensions of $24,610 and the taxable amount of such income as $19,687.

Key Issues: Whether the monthly pension distributions received by the Patrinicolas is excludable from income for federal income tax purposes?

Primary Holdings: No.

Key Points of Law:
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