IRCCourt RulingsFeb 9, 2023related by meaning
… 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…
64 T.C. 1011 — Catawba Industrial Rubber Co. v. Commissioner IRCCourt RulingsSep 9, 1975
t the trust was executed April 28, 1972. On May 30, 1972, the profit-sharing plan was communicated to petitioner’s employees by petitioner in writing. Petitioner received a favorable determination letter from the District Director of Internal Revenue, Greensboro, N.C., dated July 3,1972. That determination letter speci…
IRCCourt RulingsMay 4, 1978
…Tran advanced $13,700 and $25,950 to Huffaker for travel and entertainment expenses in fiscal years 1972 and 1973, respectively. Huffaker was required to make an accounting to Ma-Tran for such expenses. During fiscal year 1972 he submitted vouchers covering $9,869.90. During fiscal year 1973 he submitted vouchers cover…
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…
IRCCourt RulingsNov 8, 1976
…orporate income taxes:
Petitioner Year ending June 30— Deficiency
Quality Brands, Inc. 1971 $440.00
1972 440.00
Beverage Sales, Inc.. 1971 880.00
1972 4,526.67
Most of the issues have been conceded; the two issues remaining for decision are: (1) Whether a profit-sharing plan established by the petitioners qualified in …
68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner IRCCourt RulingsSep 12, 1977
…him under paragraph 1.12 and he was excluded from coverage. During FESPA’s third year of operation, 1972, there were six full-time employees working as of December 31, 1972. Three of these full-time employees, Joyce H. Reynolds, David S. Nelson, and George Podgorny, were again participants and contributions were made f…
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…
IRCCourt RulingsJun 13, 1977
…ckett’s employees were covered. For the second quarter of such fiscal year (Nov. 1, 1971 — Jan. 31, 1972), Crockett and Dorsey were covered the entire quarter, Fowler was covered as of Dec. 1, 1971, and Richardson need not be counted because she had not satisfied the minimum service requirement. Therefore, on at least …
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,…
IRCCourt RulingsAug 31, 1977
… that Ms. Whitehead was still an Albets employee at the close of Albets’ fiscal year ended July 31, 1972. On some records kept by the Traubner firm, Ms. Whitehead was carried as an Albets employee. The firm prepared the payroll tax returns for Albets for the period ended June 30, 1972, which returns showed Ms. Whitehea…
IRCCourt RulingsFeb 28, 1977
…es herein to the Internal Revenue Code are to the Code as in effect for the calendar years 1971 and 1972. For taxable years beginning after Dec. 31, 1973, substantial changes were made in the Code affecting the taxation of distributions made after that date. See sec. 2005 of the Employee Retirement Income Security Act …
IRCCourt RulingsMar 30, 1978
ner for purposes of section 401(a)(3) through November 30, 1972. As of December 1, 1972, they became employees of Partnership.
The Plan provides that: 2.01- Eligibility — Every Employee shall become a Participant under this Plan as of the Effective Date or Anniversary Date on which he first meets all of the requirement…
IRCCourt RulingsJun 3, 1998related by meaning
…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 (…
IRCCourt RulingsDec 4, 1978★ strong match
ation, and Welfare, on March 31, 1972, after 37% years of service. He retired on longevity at the age of 57, although he had been disabled since 1966. On April 27,1973, the United States Civil Service Commission approved petitioner’s application to have his retirement status changed to disability retirement, retroactiv…
IRCCourt RulingsOct 10, 1979
…lly distributed to the beneficiary, it appears that she received nothing from the trust in 1971 and 1972 and $6,500 in 1973.
Distributions in these amounts were not reflected on any of the tax returns filed for the years in question. On the trust’s various fiduciary returns for 1971 and 1972 (the first versions of whic…
IRCCourt RulingsMay 29, 2002related by meaning
… however, there was no levy by respondent in this case.
Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13,
affd. without published opinion 166 F.3d 1201 (2d Cir. 1998),
also cited by petitioner, the taxpayer was indicted on charges of
violating Federal currency transaction reporting laws. As part
of the taxpaye…
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…
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
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…
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))…