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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …e, 1954 Regulations promulgated during 1954, and effective as to facts arising on and after Jan. 1, 1955. 26 C.F.R. v (1954). 1955 revision Regulations promulgated during 1954-55, and effective as to facts arising on and after Jan. 1, 1956. 26 (pts. 1-220) C.F.R. v (1955). 1956 revision Regulations promulgated during 1…
2. 31 T.C. 1022 — Judkins v. Commissioner
   IRCCourt RulingsFeb 25, 1959
   …ility for taxes does not occur, then the effective date of termination of said Plan shall be May 5, 1955. On May 17,1955, Waterman requested a ruling regarding termination of the retirement plan. In a letter dated July 26, 1955, the Internal Revenue Service ruled that the proposed termination of the retirement plan wou…
3. 34 T.C. 73 — Zeltzerman v. Commissioner
   IRCCourt RulingsApr 18, 1960★ strong match
   …years 1950 through 1954 the petitioner stated that he was self-employed. In his return for the year 1955 he left blank the space provided for stating the name of the employer. In his return for 1956 the petitioner listed as his employers the Lancaster, Morrison, St. Louis, and Coos County Hospitals. In the joint return…
4. 40 T.C. 882 — New York Post Corp. v. Commissioner
   IRCCourt RulingsAug 26, 1963
   …led certain exhibits at the hearing. We adopt the stipulations and exhibits as our findings. During 1955 and 1956, and continuously from 1935 to 1962 (except for the period from January 14, 1939, to June 1, 1940), petitioner (sometimes referred to as the Post) operated under collective-bargaining agreements or contract…
5. 35 T.C. 405 — Coppola v. Commissioner
   IRCCourt RulingsDec 9, 1960
   …l, Judge: Respondent determined deficiencies in income tax for the taxable years ended December 31, 1955, 1956, and 1957 in the amounts of $6,225.53, $1,308.33, and $603.96, respectively. The only error assigned is that “The Commissioner has erroneously included as taxable income the employer’s contribution to pension …
6. 38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
   IRCCourt RulingsSep 21, 1962
   …s and in the amounts as follows: Year Deficiency 1952_$4,998.08 1953_ 21, 500. 66 1954_ 17, 086. 45 1955_ 48, 532.33 By amended, petition, petitioner alleged that it sustained a net operating loss for its taxable year 1957, thus becoming entitled to a net operating loss deduction for its taxable year 1955, and also cla…
7. 39 T.C. 665 — Waller v. Commissioner
   IRCCourt RulingsJan 16, 1963
   …iencies in income tax of petitioners William and Milbrey W. Waller, for the calendar years 1954 and 1955, in the respective amounts of $6,125.59 and $16,256.52, and in income tax of petitioner William Waller for the calendar year 1958 in the amount of $1,942.28. A number of concessions have been made by the parties. Th…
8. 44 T.C. 623 — Leavens v. Commissioner
   IRCCourt RulingsJul 23, 1965
   …of the distribution option set out above. He communicated his concern to petitioners. Prior to July 1955, Ives suggested to the employees that the plan be amended to eliminate this provision from the trust indenture. However, a few of the participants refused to go along with his proposal. He thereupon advised petition…
9. 54 T.C. 953 — Estate of Benjamin v. Commissioner
   IRCCourt RulingsMay 11, 1970
   … in the trust corpus became fully vested. The accumulated value of the annuity policy on November 1,1955, was $26,914.66. An agreement (hereinafter referred to as the retention agreement) dated November 1, 1955, was executed by the trustees of the Uhlmann Pension Trust requesting Mutual to retain or apply the proceeds …
10. 36 T.C. 818 — Roff v. Commissioner
    IRCCourt RulingsAug 10, 1961
    …total premiums of $18,084.86 with respect to the Prudential policy. As of its maturity date, May 1, 1955, its total cash surrender value was $22,180.59, including accumulated dividends of $88.40 and interest thereon of $47.19. On April 22,1955, petitioner executed an assignment of the Prudential policy to Sydney A. Gut…
11. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
12. 37 T.C. 817 — Wasatch Chemical Co. v. Commissioner
    IRCCourt RulingsJan 24, 1962
    …ge: The Commissioner determined deficiencies in petitioner’s income tax for the taxable years 1954, 1955, and 1956 in the amounts of $19,999.75, $21,534.64, and $19,085.54, respectively. At the hearing of this case the petitioner conceded the deficiency for the year 1954, thereby leaving for our consideration only the …
13. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
14. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
15. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
16. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
17. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
18. 34 T.C. 851 — West Virginia Steel Corp. v. Commissioner
    IRCCourt RulingsAug 15, 1960
    tter dated May 11, 1955, petitioner, by its president, Harris, wrote to the United States Treasury Department, Parkersburg, West Virginia, as follows: In accordance with instructions in your letter of February 1, 1955, we have amended our Profit Sharing Plan to meet the conditions set forth and are resubmitting our pla…
19. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
20. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    …he BCG. - 18 - questionable. See Archer v. Commissioner, 227 F.2d 270, 273 (5th Cir. 1955), affg. a Memorandum Opinion of this Court; Weiss v. Commissioner, 221 F.2d 152, 156 (8th Cir. 1955), affg. T.C. Memo. 1954-51; Schroeder v. Commissioner, T.C. Memo. 1986-467. The Court is not compelled to believe evidence that se…