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56 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …. at 12704. 113 113 The 1960 proposed regulations are identical to final regulations promulgated in 1962. T.D. 6595, 27 Fed. Reg. 3597- 3598 (Apr. 14, 1962), 1962-1 C.B. 43, 49- 51, reprinted in 26 C.F.R. sec. 1.482-1(b) (1961 ed. 1965 Cum. Supp.). We will di scuss the substance of the 1962 regulations shortly. 120 BB.…
  2. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989★ strong match
    …for taxable years beginning after Dec. 31, 1986. H. Rept. 1447 at 428, 87th Cong., 2d Sess. at 428 (1962), 1962-3 C.B. 405, 423; S. Rept. 1881, 87th Cong. 2d Sess. at 169 (1962), 1962-3 C.B. 707, 731. Cf. Sanford v. Commissioner, 50 T.C. 823, 826 (1968), affd. per curiam 412 F. 2d 201 (2d Cir. 1969), cert. denied 396 U…
  3. T.C. Memo. 2012-36 — Lisa LaFlamme v. Commissioner
    IRCCourt RulingsFeb 6, 2012
    -992 supra, 1962-3 C.B. at 303. To allow the deduction, 1962 Act sec. 3, 76 Stat. at 819, provides that a self-employed individual is considered to be her own employer and her own employee and contributions made by a selfemployed taxpayer to her pension plan "shall be considered to satisfy the conditions of section 162…
  4. 48 T.C. 75 — Pepsi-Cola Niagara Bottling Corp. v. Commissioner
    IRCCourt RulingsApr 26, 1967
    …affairs, including the hiring and firing of all employees. His salary was $28,000 for both 1961 and 1962 and $30,000 for 1963. Peter P. Seereiter served as vice president of petitioner from July 9, 1962, through December 31, 1963. His duties, both before and after assuming the executive position, involved supervising t…
  5. 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
    ed do not apply to requests for any documents to the extent § 6104 applies. Statement identifying information to be deleted from public inspection .04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
  6. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984
    …fiscal year basis beginning December 1 and ending November 30 during all years pertinent hereto. In 1962, when the trust was established, the CQmpany had approximately 50 employees. Five of these employees, including petitioner, were salaried employees covered by the trust. Two of these salaried employees earned less t…
  7. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984
    Congress added paragraph (7) to section 401(a) in 1962 (Self-Employed Individuals Tax Retirement Act of 1962, Pub. L. 87-792, sec. 2, 76 Stat. 809) in order to prevent abuses resulting from terminations of forfeitable plans. The provision was prompted by congressional concern that absent such a requirement, an owner-em…
  8. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    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,…
  9. 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…
  10. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968
    … deficiencies in income tax as follows: Docket No. Petitioner (s) FYE Nov. 30-Income tax deficiency 1962 $1,349.51 3564-66 Ed & Jim Fleitz, Inc.. 1963 339.75 1964 None 3565-66 Edward B. Fleitz and Thelma Fleitz. 1962 1963 945.13 657.33 5101-67 Edward B. Fleitz and Thelma Fleitz. 1964 1,050.31 3566-66 James J. Fleitz an…
  11. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    …sed here. Estate of Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985), affg. on this issue T.C. Memo. 1984-674, 49 T.C.M. 331, 53 P-H Memo T.C. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; Fir…
  12. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    wed do not apply to requests for any documents to the extent §6104 applies. Statement identifying information to be deleted from public inspection .04 The text of a TAM subject to §6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection.…
  13. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  14. 62 T.C. 456; 62 T.C. No. 51 — Latrobe Steel Co. v. Commissioner
    IRCCourt RulingsJul 3, 1974
    …a (hereinafter referred to as the union) had entered into a basic labor agreement effective July 26,1962 (hereinafter referred to as the 1962 agreement). With' regard to vacations, the 1962 agreement provided only for regular vacations of from 1 to 4 weeks depending on years of service. The 1962 agreement between petit…
  15. 67 T.C. 411; 1 Employee Benefits Cas. (BNA) 2232 — Hill, Farrer & Burrill v. Commissioner
    IRCCourt RulingsDec 14, 1976
    …hich accompanied the adoption of sec. 401(c)(3)(B). H. Rept. No. 378, 87th Cong., 1st Sess. (1961), 1962-3 C.B. 261, 262; S. Rept. No. 992, 87th Cong., 1st Sess. (1961), 1962-3 C.B. 303, 305. S. Rept. No. 992, supra, 1962-3 C.B. at 325. Grayck, "Tax Qualified Retirement Plans for Professional Practitioners: A Compariso…
  16. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the 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, 19…
  17. 91 FR 55462 — Federal Independent Dispute Resolution Operations; Correction
    IRCFinal Rules (FR)Aug 28, 2026related by meaning
    on, Publications and Regulations, Associate Chief Counsel, (Procedure and Administration) Department of the Treasury. In concurrence: Kurt D. Dykstra, General Counsel, Office of Personnel Management. [FR Doc. 2026-17622 Filed 8-27-26; 8:45 am] BILLING CODE 6325-63-P; 4831-GV-P; 4510-29-P; 4169-69-P
  18. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file numb…
  19. 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…
  20. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…