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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   … matters, issued pursuant to the Internal revised as of Jan. 1, 1958 Regulations promulgated during 1954-57, and effective as to facts arising on and after Jan. 1, 1958. 26 (pts. 1-19) C.F.R. v (1958). revised as of Jan. 1., 1959 Regulations promulgated during 1954-58, and effective as to facts arising on and after Jan…
2. 34 T.C. 73 — Zeltzerman v. Commissioner
   IRCCourt RulingsApr 18, 1960★ strong match
   …. Minutes of each of these meetings were kept, but were not presented in evidence. On September 13, 1954, the petitioner wrote the district director of internal revenue at Portsmouth, New Hampshire, concerning the effect which the Internal Revenue Code of 1954 might have on the situation outlined in Fels’ letter. On Se…
3. 37 T.C. 7 — Barbourville Brick Co. v. Commissioner
   IRCCourt RulingsOct 9, 1961
   petitioner’s books and records as an expense for its taxable year 1954 and was claimed as a deduction on its income tax return for such taxable year. Respondent disallowed the deduction claimed for the stated reason that “the amount of $5,100.00 claimed as a deduction for a ‘gratuity to Mrs. J. R. Bacon’ on Form 1120 …
4. 38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
   IRCCourt RulingsSep 21, 1962
   …e tax for the years and in the amounts as follows: Year Deficiency 1952_$4,998.08 1953_ 21, 500. 66 1954_ 17, 086. 45 1955_ 48, 532.33 By amended, petition, petitioner alleged that it sustained a net operating loss for its taxable year 1957, thus becoming entitled to a net operating loss deduction for its taxable year …
5. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
   IRCCourt RulingsMar 6, 2001★ strong match
   v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
6. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
   IRCCourt RulingsNov 7, 1996related by meaning
   is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   0 31 useaee CAL, Js.r. Juoca T.C. Memo. 2005-173 UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 1188-01. Filed July 14, 2005. Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens, for petitioner. Jack Forsberg,…
8. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
   IRCCourt RulingsJun 3, 1998★ strong match
   …stituted a modification of the terms of the notes. We have previously noted that a technical advice memorandum is merely a ruling given to a specific taxpayer based upon the taxpayer's specific facts and is not a ruling of general application. See Golden Belt Tel. Association, Inc. v. Commissioner , 108 T.C. 498, 506 (…
9. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
   IRCCourt RulingsApr 11, 2012related by meaning
   …red by the Joint Committee on Taxation (the Blue Book); privatd letter rulings and technical advice memoranda issued after October 31, 1976; actions on decisions and general counsel memoranda issued after March 12, 1981 (as well as general counsel memoranda published in pre-1955 volumes of the Cumulative Bulletin); Int…
10. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
11. 34 T.C. 851 — West Virginia Steel Corp. v. Commissioner
    IRCCourt RulingsAug 15, 1960
    …Corporation Profit Sharing Trust. Two employee trustees were elected on the second Tuesday of March 1954. At a meeting of the board of directors on March 26, 1954, Harris was elected as the company trustee representative. The first meeting of the trustees of West Virginia Steel Corporation Profit Sharing Trust was held…
12. 42 T.C. 993 — Barrett v. Commissioner
    IRCCourt RulingsAug 31, 1964related by meaning
    …a specific ruling on your question. Your attention is called to section 7 of Rev. Rui. 54-172, O.B. 1954r-l, 394, a reprint of which is enclosed. We are furnishing you the following general information with the understanding that it does not constitute a specific ruling. ‡ H* H« ❖ H* * Hi
13. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    …reply brief includes 4-½ pages of objections to respondent's proposed findings of fact. Id . I. The Memorandum Opinion In T.C. Memo. 1995-492, filed October 11, 1995, the Court decided the present case. In our memorandum opinion, we rejected petitioners' argument that petitioner's Transfer Refund had not been received …
14. 39 T.C. 665 — Waller v. Commissioner
    IRCCourt RulingsJan 16, 1963
    …ned deficiencies in income tax of petitioners William and Milbrey W. Waller, for the calendar years 1954 and 1955, in the respective amounts of $6,125.59 and $16,256.52, and in income tax of petitioner William Waller for the calendar year 1958 in the amount of $1,942.28. A number of concessions have been made by the pa…
15. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
16. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related by meaning
    ill be forwarded to EP or EO Technical with the request for the TAM. Taxpayer is encouraged to submit statement if Service initiates request for a TAM (2) If the request for a TAM is initiated by an EP or EO Examinations office or by an EP or EO Determinations office or by an appeals office, the taxpayer is encouraged …
17. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    …petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 1964. 1966 deduction for contributi…
18. 45 T.C. 168 — Lilly v. Commissioner
    IRCCourt RulingsNov 26, 1965
    …h of the taxable years in question is excludable from gross income under section 101 (a) (1) of the 1954 Code. The respondent contends that the amount of $1,024.92 received by petitioner during each of the taxable years in question is an annuity includable in petitioner’s gross income to the extent provided in sections…
19. PLR 201935011 — Year of Deduction
    IRCPrivate Letter RulingsAug 30, 2019
    …paid”); H.R. Rep. No. 80-2087, at 13 (1948) (“contributions actually paid”); H.R. Rep. No. 83-1337 (1954), at 43 (“pay me nts to a” qualified trust or plan) and A151 (payment “is made”); S. Rep. No. 83-1622, at 55 (1954) (“actual pay me nts”); Staff of J. Comm. on Taxation, 83rd Cong., Summary of the New Provisions of …
20. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …