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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …rnal Revenue Code of 1954, was published in the Federal Register. 30 Fed. Reg. 4256 (filed Mar. 31, 1965). Under the proposal a new paragraph (d) would be added to section 1.482-1 of the 1962 regulations, which had only three paragraphs: (a), (b), and (c). The proposed paragraph (d) would be entitled “Method of a lloca…
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. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990★ strong match
    …le” on the plan return. Section 6501(e)(3) was added to the Code by the Excise Tax Reduction Act of 1965, Pub. L. 89-44, sec. 810(b)(1), 79 Stat. 169. The Senate Report explains section 6501(e)(3) as follows: “in the case of a return which fails to list properly reportable tax, the applicable period of limitation will …
11. 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,…
12. 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…
13. 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…
14. 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))…
15. 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.
16. 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 …
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. 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 …
19. 46 T.C. 706 — Schlegel v. Commissioner
    IRCCourt RulingsAug 31, 1966
    …e plan and not on account of separation from the service. Rybacki v. Conley, 340 F. 2d 944 (C.A. 2, 1965); E. N. Funkhouser, 44 T.C. 178 (1965), on appeal (C.A. 4, Sept. 27, 1965); see Edward Joseph Glinske, Jr., 17 T.C. 562, 565 (1951).
20. 53 T.C. 344 — Stewart v. Commissioner
    IRCCourt RulingsNov 26, 1969
    …rston, Judge: Respondent determined a deficiency of $832.11 in petitioner’s income tax for the year 1965. Respondent concedes that petitioner is entitled to a credit of $676.10 for tax withheld but not claimed by petitioner on his original return for 1965. The sole issue for decision is the proper tax treatment of a lu…