IRCCourt RulingsApr 26, 2005related by meaning
…ns and to fashion equitable
remedies tö resolve these controversies." Simmons v.
Commissioner, T.C. Memo. 1995-422; see also Stevens v. Commissioner, T.C. Memo. 1985-192; Wenzel v. Commissioner, T.C.
Memo. 1982-595, affd. 707 F.2d 694 (2d Cir. 1983). Rather, in a
declaratory judgment action under section 7476, we must …
IRCCourt RulingsOct 9, 1990related by meaning
o. v. Commissioner, 30 T.C. 10, 22-23 (1958), affd. 267 F.2d 853 (7th Cir. 1959); Times Publishing Co. v. Commissioner, 13 T.C. 329, 335 (1949), affd. per curiam 184 F.2d 376 (3d Cir. 1950). Section 23(p) was reenacted as section 404 in the 1954 Code in essentially the same form. Don E. Williams Co. v. Commissioner, 42…
IRCCourt RulingsOct 28, 1965
… 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually paid by him to Ada and (b) his prorata share…
IRCCourt RulingsMar 31, 1961
…dge:
Respondent has determined deficiencies in petitioners’ income tax for the years 1954,1955, and 1956 and an addition to tax for the year 1954 as follows:
The sole issue remaining for our consideration is whether petitioners received taxable annuity income for the years in question, the disposition of this issue bei…
IRCCourt RulingsFeb 4, 1998related by meaning
ng warned by the Court
and after having received notice from the Court in a prior case.
6
On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's
position is both frivolous and groundless. Accordingly, we
exercise our discretion and award a penalty t…
IRCCourt RulingsJan 16, 2002related by meaning
…nial of
equitable relief under the last sentence of section 66(c). Beck
- 9 -
v. Commissioner, T.C. Memo 2001-198. Here, we review
respondent's denial of equitable relief under section 66(c) for
abuse of discretion. Id ; see also Fernandez v. Commissioner,
114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
IRCCourt RulingsMar 17, 1987
… in Pittsburgh, Pennsylvania, when their petition was filed.
Gordon was born on August 26, 1921. In 1956, he and Bernard J. Tepper formed United Baking Co., and at all relevant times owned the United Baking stock equally. Between 1969 and 1978 Gordon served as president.
In 1956, the company adopted the United Baking C…
IRCCourt RulingsAug 26, 1980related by meaning
r further proceedings on the merits. Federal Land Bank Association of Asheville, North Carolina, et al. v. Commissioner, 573 F.2d 179 (4th Cir. 1978). On April 23, 1976, petitioners filed petitions with this Court for declaratory relief pursuant to section 7476 1 which provides for declaratory judgments relating to qua…
IRCCourt RulingsAug 31, 1956
…ondent
Electric Materials Co. v. Commissioner
Docket No. 54922
United States Tax Court
26 T.C. 997; 1956 U.S. Tax Ct. LEXIS 103;
August 31, 1956, Filed
*103 Decision will be entered for the respondent.
Excess Profits Tax (Korean War) -- Adjustment for Abnormality -- Abandonment -- Consequence of Change in Manner of Ope…
IRCCourt RulingsDec 23, 1996related by meaning
…e year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-556
UNITED STATES TAX COURT
ALFRED P. DUFFY, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6723-93. Filed December 23, 1996.
Alfred P. Duffy, pro se.
Judith Wilkie
, for respondent.
ME…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…-1 C.B. 128; Rev. Rul. 77-293, 1977-2 C.B. 91; Rev. Rul. 57-387, 1957-2 C.B. 225; Rev. Rul. 56-584, 1956-2 C.B. 179; or Rev. Rul. 56-556, 1956-2 C.B. 177.
(54) Section 302(b)(4) and (e).—Redemption from Noncorporate Shareholder in Partial Liquidation; Partial Liquidation Defined.—The amount of working capital attributa…
IRCPrivate Letter RulingsMar 3, 2000related by meaning
…C:EBEO:4
TL-N-4712-99
UILC: 419.00-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR
FROM: Assistant Chief Counsel (Employee Benefits and Exempt
Organizations) CC: EBEO
SUBJECT:
This Field Service Advice is in res ponse to your memorandum dated October 5,
1999. Field Service Advice is not …
Rev. Rul. 2025-2 — Section 401. — Qualified Pension, Profit-Sharing, and Stock Bonus Plans IRCRevenue RulingsJan 13, 2025
…50
2016
75,180
1951
2017
77,880
1952
2018
80,532
1953
2019
83,244
1954
2020
86,052
1955
2022
91,884
1956
2023
95,172
1957
2024
98,616
1958
2025
102,180
1959
2026
105,684
1960
2027
109,140
1961
2028
112,524
1962
2029
115,824
1963
2030
119,100
1964
2031
122,340
1965
2032
125,508
1966
2033
128,580
1967
2034
131,544
1968
2…