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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …d. Reg. 3597- 3598 (Apr. 14, 1962), 1962-1 C.B. 43, 49- 51, reprinted in 26 C.F.R. sec. 1.482-1(b) (1961 ed. 1965 Cum. Supp.). We will di scuss the substance of the 1962 regulations shortly. 120 BB. The creation of a new title of the Code of Federal Regulations In 1961 the Government Printing Office issued a new title …
2. 46 T.C. 431 — John C. Nordt Co. v. Commissioner
   IRCCourt RulingsJun 24, 1966
   …Inc_. John C. Nordt Co., Inc.. John C. Nordt Co., Inc_. Bertha C. Nordt_ Frieda C. Nordt_ 1959 1960 1961 1961 1961 $538.79 2,084.23 1,500.00 160.76 228.18 In docket No. 1153-65, Bertha claims an overpayment for 1961 instead of a deficiency. Three issues are involved: 1. Did the respondent err in disallowing $1,846.32 o…
3. 48 T.C. 75 — Pepsi-Cola Niagara Bottling Corp. v. Commissioner
   IRCCourt RulingsApr 26, 1967
   …orporate affairs, including the hiring and firing of all employees. His salary was $28,000 for both 1961 and 1962 and $30,000 for 1963. Peter P. Seereiter served as vice president of petitioner from July 9, 1962, through December 31, 1963. His duties, both before and after assuming the executive position, involved supe…
4. 54 T.C. 953 — Estate of Benjamin v. Commissioner
   IRCCourt RulingsMay 11, 1970
   …: Respondent determined a deficiency of $9,838.18 in the income tax of petitioners for taxable year 1961. The issues presented for decision are (1) whether petitioners are entitled to capital gains treatment upon the surrender of an annuity policy and receipt of the balance payable in a lump sum (under section 402 or s…
5. 42 T.C. 299 — Sherwood Swan & Co. v. Commissioner
   IRCCourt RulingsApr 30, 1964
   fiscal years 1959, 1960, and 1961, the amounts of petitioner’s assets contained in the profit-sharing trust account of Sherwood Swan were as follows: Trust account balance of Sherwood Swan Sherwood Swan’s percent age of total beneficiaries’ equities Fiscal year $62,546.14 45.65 1959. 66,314.87 54.92 1960. 69,662.04 54…
6. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
   IRCCourt RulingsJan 31, 1973★ strong match
   …ude v. Commissioner, 372 U.S. 128 (1963), American Automobile Assn. v. United States, 367 U.S. 687 (1961), and Commissioner v. Milwaukee & Suburban Transport Corp., 367 U.S. 906 (1961), which require a decision against the taxpayer herein. While it is true that the Schlude and American Automobile eases were concerned w…
7. 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))…
8. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
   IRCCourt RulingsMay 30, 1984
   … view, not organizations described in section 501(c)(3). See S. Rept. 730, 87th Cong., 1st Sess. 2 (1961), 1961-2 C.B. 466, 467. See also Rev. Rui. 60-384, 1960-2 C.B. 172. As a result, in 1961, Congress amended section 403(b) (see Pub. L. 87-370, 75 Stat. 796, 801) to permit annuity contracts purchased for public scho…
9. 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…
10. 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…
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. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    …etermination letters shall have limited application * * * See also Vernaccini v. Commissioner, T.C. Memo. 1974-66. Some of the cited cases raise the question of the application of secs. 165(a) and 23(p), I.R.C. 1939, to a determination of the proper effective date of trust instruments adopted by accrual basis taxpayers…
13. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
14. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968
    …tipulated and they are so found. Ed & Jim Fleit,z, Inc., an Ohio corporation, formed on J anuary 3, 1961, had its principal office in Oregon, Ohio, at the time its petition was filed. The legal residences of the individual petitioners at the time their petitions were filed were Oregon, Ohio, for Edward B. and Thelma Fl…
15. 24 T.C. 460 — Northwest Automatic Products Corp. v. United States
    IRCCourt RulingsJun 23, 1955related by meaning
    h respect to this matter is hereby set for_ at_if that time is not convenient, kindly advise us promptly in order that a continuance may- be arranged. This notice, sent by registered mail, constitutes commencement of the renegotiation proceedings in conformity with the provisions of subsection (c) (1) of the Renegotiat…
16. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
17. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    IRCCourt RulingsOct 29, 2002
    …ment is taxable in 1996. ¹ Petitioner conceded in his reply brief that Cowden v. Commissioner, T.C. Memo. 1961-229, and the cash equivalency and economic benefit doctrines do not support his contention that he received all of the lottery winnings in 1989. h _ 9 _ D. Whether Petitioner May Exclude His NYSL Winnings Beca…
18. T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers …
    IRCTreasury DecisionsSep 29, 2003related by meaning
    rders) applies for transfers, distributions, and payments made after December 31, 2001. Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows: Authority: 26 U.S.C. 7805. Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
19. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
20. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    a tax professional. Cf. Streber v. Commissioner , 138 F.3d 216 (5th Cir. 1998), revg. T.C. Memo. 1995-601; Reser v. Commissioner , 112 F.3d 1258 (5th Cir. 1997), affg. in part and revg. in part and remanding T.C. Memo. 1995-572; Chamberlain v. Commissioner , 66 F.3d 729 (5th Cir. 1995), affg. in part revg. in part T.C.…