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…
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…
T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner IRCCourt RulingsJun 17, 1998
…10,
1988, the IRS published temporary guidance to taxpayers for
transfers occurring after April 30, 1989, that would be subject to section 7520. Notice 89-24, 1989-1 C.B. 660, published on
March 6, 1989, sets forth the formulas for computing the present
value of an annuity on the basis of the appropriate applicable
Fed…
IRCCourt RulingsSep 18, 1996★ strong match
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
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 RulingsSep 25, 1996★ strong match
…61 F.2d 494 (7th Cir. 1988),
affd. sub nom. Ratliff v. Commissioner
, 865 F.2d 97 (6th Cir.
- 125 -
1989), affd. sub nom. Kirchman v. Commissioner
, 862 F.2d 1486
(11th Cir. 1989), Killingsworth v. Commissioner
, 864 F.2d 1214
(5th Cir. 1989); affd. sub nom. Keane v. Commissioner
, 865 F.2d
1088 (9th Cir. 1989), affd. …
IRCCourt RulingsOct 29, 2002
ing in 1989. The NYSL did not
offer petitioner the option of receiving a lump-sum payment in
1989. Petitioner was employed by the Consulate General of Nigeria when he won the lottery. He used the cash method of
accounting in 1989.
Petitioner received two or three offers to buy the rights to
his future lottery winnings …
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 RulingsOct 17, 1995★ strong match
…ns of
petitioners herein. Lerch v. Commissioner
, 877 F.2d 624, 631-632
(7th Cir. 1989), affg. T.C. Memo. 1987-295; Geiger v.
Commissioner
, 440 F.2d 688, 689-690 (9th Cir. 1971), affg. per
curiam T.C. Memo. 1969-159. The determination of respondent is
sustained as to rental expenses claimed in 1989 and 1990.
Issue 7. …
IRCCourt RulingsAug 15, 1994
…est was signed by Samuel J. Sirota, an attorney and a certified public accountant, on September 15, 1989. On September 15, 1989, the corporation timely filed its Federal income tax return, Form 1120S, for its taxable year ended June 30, 1989. The corporation did not claim a deduction for the contributions, if any, it m…
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 …
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…executive compensation of CEO's
by industry categories as of May 1990, showing results for the
year 1989 classified under all industries and categories of
industries for companies that had sales of approximately $162
million:
Title
Year
Sales
Average
+1 SD
+2 SDs
All Industries
CEO 1989 $162.416 $340.72 $497.96 $655.21…
109 T.C. No. 21 — Lakewood Associates; Robert G. Moore, Tax Matters Partner v. Commissioner IRCCourt RulingsDec 29, 1997
… of the property pursuant to the 1989
Manual.
- 7 -
In November 1989, the Corps also entered into a Memorandum
of Agreement (MOA) with the EPA that establishes the procedures
to be used by the Corps staff in reviewing section 67(a) (section
404) CWA permit applications. Specifically, the MOA articulated
IRCCourt RulingsNov 2, 1998
… findings of
fact and opinion with respect to each issue.
Issue 1. Statutory Period of Limitations--1989
Petitioner asserts that he timely filed a 1989 tax return and
therefore maintains that the period for assessing a deficiency and
additions to tax against him for 1989 expired before the date on
which respondent mail…
ERISACourt RulingsJan 20, 1998
…g annual
rates were applicable during the course of this transaction:
December 1988, 8.40%; January 1989, 9.01%; February, 9.30%; March,
9.30%; April, 9.62%; May, 9.82%; June, 9.39%; July, 8.86%; August,
8.34%; September, 8.07%; and October, 8.45%. The average annual
rate over this period was 8.96%. This is the rate I …
IRCCourt RulingsDec 19, 1995★ strong match
…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…
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 (…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…0
04/01/1988
06/01/1988
7.75
06/01/1988
09/01/1988
8.00
09/01/1988
11/01/1988
8.25
11/01/1988
04/01/1989
7.75
04/01/1989
06/01/1989
8.00
06/01/1989
08/01/1989
7.75
08/01/1989
09/01/1989
7.50
09/01/1989
10/01/1989
7.25
10/01/1989
12/01/1989
7.50
12/01/1989
03/01/1990
7.25
03/01/1990
06/01/1990
7.50
06/01/1990
07/01/1990…
IRCCourt RulingsOct 25, 2012
…spondent issued a favorable determination letter. The plan was amended and
restated on November 18, 1989 (1989 plan), effective for the fiscal year beginning
July 1, 1989. The 1989 plan was amended on June 23, 1997, and June 5, 1998.
On September 13, 2001, the 1989 plan was amended and restated (2001 plan).
The 1989 pl…
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…