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73 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 124 T.C. No. 12 — Charles P. Stepnowski v. Commissioner
    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 …
  2. 95 T.C. 415; 95 T.C. No. 30 — Albertson's, Inc. v. Commissioner
    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…
  3. 45 T.C. 133 — Jacobs v. Commissioner
    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…
  4. 35 T.C. 1217 — Searl v. Commissioner
    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…
  5. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    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…
  6. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    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…
  7. 88 T.C. 630; 88 T.C. No. 34 — Gordon v. Commissioner
    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…
  8. 74 T.C. 1106; 2 Employee Benefits Cas. (BNA) 2385 — Federal Land Bank Asso. v. Commissioner
    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…
  9. 26 T.C. 997 — Electric Materials Co. v. Commissioner
    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…
  10. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    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…
  11. 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…
  12. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …
  13. 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…