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81. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    rences are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-perc…
82. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    …halt Prods. Co., 482 U.S. 117, 121 (1987).] See also Griffin v. Oceanic Contractors, Inc., 458 U.S. 564, 571 (1982); United States v. Mansfield Tire & Rubber Co., 942 F.2d 1055, 1058 (6th Cir. 1991). Here, we do not find respondent’s interpretation of section 419A(c)(2) to be unreasonable. Quite the opposite, as the ca…
83. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    Featherston, Judge: Respondent has determined that each of the petitioners in these consolidated cases is liable as a transferee for income tax deficiencies due from 2560 Corp. (formerly B-G Equipment Co., Inc.), transferor, for the taxable years ended March 31, 1967, and March 31, 1968. The deficiencies so determined …
84. 85 T.C. 1031; 85 T.C. No. 60 — Anesthesia Service Medical Group, Inc. v. Commissioner
    IRCCourt RulingsDec 24, 1985
    …; Commissioner v. Treganowan, 183 F.2d 288, 290 (2d Cir. 1950); Tighe v. Commissioner, 33 T.C. 557, 564 (1959).
85. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003related by meaning
    ng this amount. Subsequently, J.D. merged into Clarkston pursuant to section 368, and filed a final tax return as a C corporation for the period ended April 30, 2000. The $90,000 intercompany note was during the final return year of J.D. eliminated by book entry as a result of the merger. - 5 - Discussion Respondent’s …