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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …Supp.). Meanwhile, two successive new editions of the Code of Federal Regulations were published in 1967 and 1968. Each reprinted the 1962 regulations. 26 C.F.R. sec. 1.482-1 (1967); 26 C.F.R. sec. 1.482-1 (1968). The 1967 revision to the Code of Federal Regulations contained regulations promulgated on or before Decemb…
2. 57 T.C. 278 — Richards v. Commissioner
   IRCCourt RulingsNov 24, 1971
   …her pro-rata share of the earnings on his or her Dishursable Portion for the period from January 28,1967, to and including June 30,1967. Section 1.3 The total earnings of the Trust for the fiscal year ended June 30, 1967, less the amount of earnings paid out as provided in the immediately preceding Section 1.2 shall be…
3. 62 T.C. 150; 62 T.C. No. 18 — Farley Funeral Home, Inc. v. Commissioner
   IRCCourt RulingsMay 13, 1974
   … Schimmel, Farley, and Estes carried on the business from 1958 until petitioner was incorporated in 1967. From the date of incorporation, October 9, 1967, continuing through the years in issue, these three persons each owned 33y3 shares of petitioner’s common stock and were officers and directors of petitioner. During …
4. 63 T.C. 11 — Gillis v. Commissioner
   IRCCourt RulingsOct 2, 1974
   …ies received 0 $24,998.84 (2,098.53) Aug. 31,1966 Securities received 0 5,003.30 (7,101.83) Mar. 31,1967 Accrual-receivable 34,498.38 0 27,396.55 May 17,1967 Securities received 0 3,159.88 24,236.67 Dec. 20,1967 Securities received 0 5,694.65 18,542.02 Mar. 31,1968 Accrual-receivable 36,044.15 . 0 54,586.17 Mar. 31,196…
5. 63 T.C. 255; 1 Employee Benefits Cas. (BNA) 1135 — Harwood Associates, Inc. v. Commissioner
   IRCCourt RulingsNov 26, 1974
   zation payment 1967 _ $100 8/18/67 8/31/67 1,900 11/15/67 1968 _ 2,000 8/8/68 10/7/68 1969 ^_ 1,000 8/22/69 8/29/69 1970 _ 9,000 (Undisclosed) 8/31/70 By a letter dated October 25, 1967, petitioner’s authorized representative requested that the district director of internal revenue, Buffalo, N.Y., issue a determination…
6. 61 T.C. 727; 61 T.C. No. 78 — Robertson v. Commissioner
   IRCCourt RulingsMar 13, 1974
   …eficiencies in Federal income taxes of the petitioners as follows: Docket No. Year Amount 3088-71__ 1967 $3, 283. 98 3089-71_ 1967 2,438.55 3090-71_ 1967 3, 105. 26 3205-71_ 1967 1, 957. 53 Upon joint motion by the parties, these cases were consolidated for trial, briefs, and opinion. Certain concessions have been made…
7. 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 (…
8. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
   IRCCourt RulingsMay 26, 1976
   …t determined the following deficiencies in petitioner’s Federal income taxes: TYEAPR.30— Deficiency 1967_ $168,077.53 1968_ 156,568.00 Two issues require consideration: (1) Whether a downward adjustment should be made to the foreign tax credit claimed by petitioner for the taxable year ended April 30, 1967, and (2) whe…
9. 68 T.C. 929 — Jobusch v. Commissioner
   IRCCourt RulingsSep 19, 1977
   …ers in the firm. With these ideas in mind, Friedman and Jobusch caused the Corporation, on June 14, 1967, to adopt a stock bonus plan and enter into an agreement with Friedman, Jobusch, and Richard E. Mc-Clanahan, one of Corporation’s senior employees, as trustees, for the creation of a stock bonus trust under the plan…
10. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    ciency, id. , petitioner cites Chrysler Corp. v. Brown , 441 U.S. 281 (1979), for the proposition that respondent’s reopening procedures in Rev. Proc. 94-68, 1994-2 C.B. 803, should have “the force and effect of law”. Chrysler Corp. v. Brown , 441 U.S. at 302 (quoting Morton v. Ruiz , 415 U.S. 199, 232, 235, 236 (1974)…
11. 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))…
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. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
14. 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 …
15. 58 T.C. 940 — Funkhouser v. Commissioner
    IRCCourt RulingsSep 11, 1972
    …nts as follows: Calendar year Amount Calendar year Atnount 1964 _$89. 50 1966_103. 00 1965 _ 87. 47 1967 _109.25 Respondent determined deficiencies in the Federal income taxes of petitioners Arthur D. Burnett (hereinafter referred to as Burnett) and Anne B. Burnett for the years and in the amounts as follows: Calendar …
16. 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…
17. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
18. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    y appropriate case in the future. At the commencement~of trial in this case this Court reminded petitioner of the prior admånishment, reading directly from the earlier opinion as well as stressing that we did not have jurisdiction over the validity of the Texas State court garnishment order. We told petitioner to restr…
19. T.C. Summary Opinion 2014-18 — Thomas Wesley Alexander & Sylvia Alexander v. Commissioner
    IRCCourt RulingsFeb 26, 2014related by meaning
    …nces of his or her transactions. Bezdjian v. Commissioner, 845 F.2d 217 (9th Cir. 1988), aff'g T.C. Memo. 1987-140; Carlton v. United States, 385 F.2d 238, 243 (5th Cir. 1967) (citing Commissioner v. Duberstein, 363 U.S. 278, 286 (1960)). What actually was done determines the tax treatment of a transaction. Weiss v. St…
20. 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…