Search the Pension Law Library

81. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975related by meaning
    ter the alleged transfer because they performed the same services for the partnership under the continuing control and supervision of the partnership. We also note that respondent issued two additional revenue rulings dealing with this subject several days ago. In Rev. Rul. 75-35,1.R.B. 1975-6, 6, the facts were somewh…
82. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976
    …oner, 238 F.2d 589 (3d Cir. 1956), revg. 25 T.C. 924 (1956), and H. S. D. Co. v. Kavanagh, 191 F.2d 831, 846 (6th Cir. 1951). In view of such material changes, the petitioner was no longer justified in relying upon the Commissioner’s earlier rulings. Cf. secs. 601.201(a)(2) and (3), 601.201(1)(5), and 601.201(m), State…
83. 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 …
84. 70 T.C. 1001; 1 Employee Benefits Cas. (BNA) 1981 — Pulver Roofing Co. v. Commissioner
    IRCCourt RulingsSep 19, 1978
    … the ruling issued to petitioner in 1959. Petitioner’s reliance on H.S.D. Co. v. Kavanagh, 191 F.2d 831 (6th Cir. 1951), is misplaced.. That case involved an attempt by a new Commissioner of Internal Revenue to revoke a prior ruling where there had been no change whatsoever in the facts and, at most, a mistaken inferen…
85. 37 T.C. 78 — Hayward v. Commissioner
    IRCCourt RulingsOct 25, 1961related by meaning
    recognized in section' ⅞,1 of. its regulations, set forth above. See the last sentence of section 405(b) of the Defense Production Act of 1950, supra. We are not here called upon to decide whether taxpayers may appeal from the dis-allowance to us or any other court (see N. A. Woodworth Co. v. Kavanagh, supra; Oak Mfg. …
86. 63 T.C. 267 — Cohen v. Commissioner
    IRCCourt RulingsNov 26, 1974related by meaning
    o him under the provisions of section 165(b), I.R.C. 1939, which contained provisions comparable to those of section 402(a), until distributed to him. In the Megibow case we stated in part (21 T.C. at 199-200):
87. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
88. 85 T.C. 1031; 85 T.C. No. 60 — Anesthesia Service Medical Group, Inc. v. Commissioner
    IRCCourt RulingsDec 24, 1985
    …e statutes.” Commissioner v. South Texas Lumber Co., 333 U.S. 496, 501, 68 S.Ct. 695, 698, 92 L.Ed. 831 (1948); accord, Fulman v. United States, 434 U.S. 528, 533, 98 S.Ct. 841, 845, 55 L.Ed.2d 1 (1978); Bingler v. Johnson, 394 U.S. 741, 749-751, 89 S.Ct. 1439, 1444-1445, 22 L.Ed.2d 695 (1969). * * * [Commissioner v. P…
89. 91 T.C. 769; 91 T.C. No. 49 — Estate of Christmas v. Commissioner
    IRCCourt RulingsOct 6, 1988related by meaning
    n of the transitional rule and denial of the unlimited marital deduction is, therefore, consistent with, and does not frustrate, congressional intent. Because we have concluded that the marital deduction provision in decedent’s will is a marital deduction formula to which section 403(e)(3) of ERTA applies, the marital …
90. 78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
    IRCFinal Rules (FR)Sep 19, 2013
    …bilitation, modernization, and improvement to the property. See, for example, Moss v. Commissioner, 831 F.2d 833 (9th Cir. 1987); United States v. Wehrli, 400 F.2d 686 (10th Cir. 1968); Norwest Corp. v. Commissioner,