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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   … and June 30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M. (CCH) 1707 (a case involving tax years 1979, 1980, and 1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d 825 (5th Cir. 1996) In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
2. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
   IRCCourt RulingsJan 31, 1973★ strong match
   …last anniversary date of his employment prior to the termination of his employment. As of March 27, 1965, the end of the first fiscal year that petitioner had operated under the 1964 employment agreement, petitioner had paid to employees whose second anniversary date of employment had fallen during that fiscal year $14…
3. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
   IRCCourt RulingsJul 25, 1974
   ust agreement is taxable to the decedent James Max Harrison in 1965. The decedent reported on the cash receipts and disbursements basis of accounting. Petitioners contend, as the employment contract states, that the $50,000 was payment for future consulting services and for an agreement not to work for competitors. Pet…
4. 56 T.C. 1142 — Evans v. Commissioner
   IRCCourt RulingsAug 23, 1971
   …s, Judge: Respondent determined a deficiency in income tax against petitioners for the taxable year 1965 in tfie amount of $8,495.57. Tfie issue presented for decision is tfie amount, if any, includable in petitioners’ income on account of tfie receipt during 1965 from a qualified pension trust following tfie trust’s t…
5. 55 T.C. 1144 — Loevsky v. Commissioner
   IRCCourt RulingsMar 31, 1971
   as filed. They filed joint Federal income tax returns for the taxable years 1964 and 1965 with the district director of internal revenue, Newark, N.J. George Loevsky and Euth Loevsky are husband and wife who resided in Lyndhurst, N. J., when the petition herein was filed. They filed joint Federal income tax returns for…
6. 60 T.C. 227; 60 T.C. No. 27 — Tobey v. Comm'r
   IRCCourt RulingsMay 17, 1973
   attorney in Seattle. During 1964,1965, and 1966, except for three very short visits to the United States, petitioner was physically present in Europe. Petitioner filed Federal income tax returns on the cash basis for taxable years 1965 and 1966 with the Director of International Operations, Washington, D.C. Petitioner’…
7. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
   IRCCourt RulingsMar 6, 2001★ strong match
   …v. United States , 421 F.2d 475 (6th Cir. 1970); Geurkink v. United States , 354 F.2d 629 (7th Cir. 1965); Luhring v. Glotzbach , 304 F.2d 560 (4th Cir. 1962); Collins v. Commissioner , supra ; Notaro v. United States , 71 AFTR 2d 93-659, 93-1 USTC par. 50,030 (N.D. Ill. 1992); First Fed. Sav. & Loan Association v. Gol…
8. 62 T.C. 456; 62 T.C. No. 51 — Latrobe Steel Co. v. Commissioner
   IRCCourt RulingsJul 3, 1974
   …f accumulated continuous service, who were eligible on December 31, 1964, for a regular vacation in 1965, exclusive of those employees who became vested for the 13 weeks of extended vacation pay in 1964, would be entitled to 13 weeks of extended vacation pay on January 1, 1965. 3. All those employees who were eligible …
9. 54 T.C. 702 — Republic Engineers, Inc. v. Commissioner
   IRCCourt RulingsMar 31, 1970
   30, 1965, Utilities was indebted to that corporation in the amount of $7,500. The liabilities of Utilities per books exceeded its assets by $1,483.10. The petitioner was organized on August 17, 1965, by Homer A. Hunter and R. Frederick Hunter. On August 26, 1965, acting on behalf of herself and as administratrix of her…
10. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
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. 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
    P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
13. 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…
14. 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
    P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
15. 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))…
16. Treas. Reg. § 1.1563-2(c)(2) — Excluded stock.
    IRCRegulationsDec 30, 2024
    …he provisions of this paragraph may be illustrated by the following example: Example.On each day of 1965, corporation P owns directly 50 of the 100 shares of the only class of stock of corporation S. Jones, an officer of P, owns directly 30 shares of S stock and P has an option to acquire such 30 shares from Jones. The…
17. 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 (…
18. Treas. Reg. § 1.101-2(d)(4)(iii) — Employees' death benefits.
    IRCRegulationsJan 19, 2017
    …uary 1, 1960, and the other half of his interest changed to a nonforfeitable interest on January 1, 1965. On January 1, 1965, the cash surrender value of the annuity contract was $6,000.
19. T.C. Summary Opinion 2005-78 — Hossam Helmy El-Bibany & Salma Hassan Kandil v. Commissioner
    IRCCourt RulingsJun 8, 2005
    …for such period in the cost of attendance (as defined in section 472 of the Higher Education Act of 1965, 20 U.S.C. 1087ll, as in effect on the date of the enactment of this paragraph) for the eligible educational institution for such period. - 9 - 10 The Higher Education Act of 1965, Pub. L. 89-329, 79 Stat. 1219, 20 …
20. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…