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Go to T.C. Memo. 1956-226 (not yet in the library — opens the official source)
69 documents · 0.56sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    … and June 30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M. (CCH) 1707 (a case involving tax years 1979, 1980, and 1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d 825 (5th Cir. 1996) In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
  2. 34 T.C. 73 — Zeltzerman v. Commissioner
    IRCCourt RulingsApr 18, 1960
    …s of the compensation formula for services performed by the petitioner during the year 1955. During 1956 the Lancaster Hospital continued to deposit checks in the savings account, based upon petitioner’s percentage of X-ray charges. The balance in such account on December 28, 1956, was $8,795.63, of which $8,794.37 was…
  3. 38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
    IRCCourt RulingsSep 21, 1962
    …to close out existing contribution credit accounts. At a meeting of the subscribers on February 25, 1956, a resolution that the balance due on the original certificate of contribution be retired immediately was adopted, this resolution also containing provisions in accordance with the plan which had been set forth by t…
  4. 40 T.C. 882 — New York Post Corp. v. Commissioner
    IRCCourt RulingsAug 26, 1963
    For some years prior to and continuing at least through the tax years 1955 and 1956, the Post maintained on its books a reserve for severance pay. During 1955 and 1956 the Post made book entries reflecting increments to that reserve for its anticipated liability in respect of (1) Guild employees who had not yet reached…
  5. 44 T.C. 623 — Leavens v. Commissioner
    IRCCourt RulingsJul 23, 1965
    … No. Deficiency Additions to tax under sec. 6651(a) I.R.C. 1954 William B. and Emeline Leavens, Jr. 1956 2103-63 $18,007.95 1957 791-63 23,469.63 1958 791-63 27, Oil. 67 1959 791-63 45,817.09 Robert C. and Mae C. Glass. 1956 964-63 10,286.93 1957 964-63 13,348.04 1958 964-63 15,713.89 1959 964-63 28,002.67 John and Mar…
  6. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968
    …ch congressional intent in the legislative history of the section. H.R. 9893, 84th Cong., 2d Sess. (1956); H. Rept. No. 1890, 84th Cong., 2d Sess. (1956); S. Rept. No. 2364, 84th Cong., 2d Sess. (1956); H. Rept. No. 2641, 84th Cong., 2d Sess. (1956); H.R. 12270, 84th Cong., 2d Sess. (1956); S. Rept. No. 2775, 84th Cong…
  7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    0 31 useaee CAL, Js.r. Juoca T.C. Memo. 2005-173 UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 1188-01. Filed July 14, 2005. Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens, for petitioner. Jack Forsberg,…
  8. 50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner
    IRCCourt RulingsMay 29, 1968
    …w union contracts on July 2, 1952, and July 2, 1954. The latter contract was effective until May 31,1956. Hone of the union contracts which were in effect up to that date contained any provision for severance pay. On September 12,1956, petitioner and local 812 entered into a union contract which was effective from June…
  9. 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))…
  10. 37 T.C. 817 — Wasatch Chemical Co. v. Commissioner
    IRCCourt RulingsJan 24, 1962
    …mmissioner 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 years 1955…
  11. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010★ strong match
    …such as stockholders or employees . Fo r instance, in Commissioner v . LoBue , 351 U .S . 243, 248 (1956), the Supreme Court observed that although " our taxing system has ordinarily treated an arm's length purchase of property even at a bargain price as giving rise to no taxable gain in the year of purchase * * * that…
  12. 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. …
  13. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    …stituted a modification of the terms of the notes. We have previously noted that a technical advice memorandum is merely a ruling given to a specific taxpayer based upon the taxpayer's specific facts and is not a ruling of general application. See Golden Belt Tel. Association, Inc. v. Commissioner , 108 T.C. 498, 506 (…
  14. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976
    …tion. The cases cited by the petitioner — Lesavoy Foundation v. Commissioner, 238 F.2d 589 (3d Cir. 1956), revg. 25 T.C. 924 (1956); H. S. D. Co. v. Kavanagh, supra — in support of its position are clearly distinguishable from the situation herein. In those cases, there was no material change in the operation of the pl…
  15. 35 T.C. 405 — Coppola v. Commissioner
    IRCCourt RulingsDec 9, 1960
    …ge: 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 plan o…
  16. 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…
  17. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
  18. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …), affd. without published opinion 578 F.2d 1383 (8th 042 Cir. 1978); Bartley v. Commissioner, T.C.·Memo. 1998-322; Ruben v. Commissioner, T.C. Memo. 1987-277; Downing v. Commissioner, T.C. Memo. 1983-97; Warren v. Commissioner, T.C. Memo. 1982-696; Notter v. Commissioner, T.C. Memo. 1982-96; Cunninghman v. Commissione…
  19. 63 T.C. 267 — Cohen v. Commissioner
    IRCCourt RulingsNov 26, 1974★ strong match
    that the same arguments were not present in those cases which are being presented in the instant case and that those cases were not fully considered. Petitioners further contend that the holdings in the Taylor and Megibow cases treat a Federal civil service employee differently from the treatment accorded to employees…
  20. 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’ …