IRCCourt RulingsDec 24, 1985related by meaning
terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange.
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…elding
Grey Adv., 1,558,784 1,748,268 1,943,815 1,979,855
Inc.
2
Greenstone 305,000 250,000 377,051 367,000
Roberts
Adv.
3
Interpublic 1,652,525 1,705,044 1,635,232 1,437,983
Group of
Cos.
4
Laser N/A N/A N/A 109,826
Vision
Centers, Inc.
Omnicom Group 780,000 957,500 1,053,750 1,168,750
75th %tile 965,600 964,800 1,106…
IRCCourt RulingsFeb 10, 1997related by meaning
ith respect to our Opinion.
In our Opinion, we held that petitioner may not deduct in a
single taxable year contributions to 29 collectively bargained defined benefit plans made over a period of 20 (in some cases 19)
months. In the Motion petitioner alleges that the Court erred in
that this holding contradicts 20 years…
IRCCourt RulingsAug 26, 1980related by meaning
th the statute and the Congress' policy.
It may be that the regulations could validly prevent such a conditioning of administrative committee consent. This is not an occasion to deliver an advisory opinion as to the validity of a hypothetical regulation, but merely an observation that the status of such a hypothetical …
IRCCourt RulingsOct 2, 1974related by meaning
may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
t it was final and conclusive and not to be reopened except “upon a showing of fraud or malfeasance or a wilful misrepresentation of a material fact.” In view of the foregoing we conclude that the separate identity of the petitioner and the other two corporations must be recognized in these rebate proceedings. Section …
IRCCourt RulingsApr 2, 2024related by meaning
, 1485 (2021)
(“ [A]s this Court has long made plain, pleas of administrative
inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105,
2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is
clear, that is the…
IRCCourt RulingsOct 12, 1978related by meaning
levant documents comprising the application for determination. Such information was furnished to the Department of Labor by the IRS on April 20, 1977. On May 25, 1977, the Commissioner notified the trustees of Central that its plan, as amended effective January 30, 1976, was qualified, provided it adopted the additiona…
IRCCourt RulingsSep 11, 1972related by meaning
tation of that section. Petitioners contend that Eev. Eul. 69-544 is at variance with the plain wording of section 1.72-16 (b) (6) of the regulations. In Raymond J. Moore, 45 B.T.A. 1073 (1941), we held that the portion of the premiums paid by a qualified pension trust for the benefit of employees for an annuity contra…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
g the term "employer reversion"
subsection (c) begins with the words "For purposes of this
section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for
purposes of the income tax
. Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissione…