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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   … “Title 26--Internal Revenue” of the Code of Federal Regulations wer e published in 1955, 1956, and 1957. 26 C.F.R. (Supp. 1955); 26 C.F.R. (Supp. 1956); 26 C.F.R. (Supp. 1957). Added pocket parts to be used in conjunction with the 1957 pocket supplement were published in 1958, 1959, and 1960. 26 C.F.R. (Supp. 1957 & a…
2. 38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
   IRCCourt RulingsSep 21, 1962
   …SNAR loss was uncollectable. Teitelbaum, v. Commissioner, 294 F. 2d 541 (C.A. 7, 1961), affirming a Memorandum Opinion of this Court, certiorari denied 368 U.S. 987; American Equitable Assurance Co. of N.T. v. Helvering, 68 F. 2d 46 (C.A. 2, 1933), affirming a Memorandum Opinion of this Court; and W. A. Dallmeyer, 14 T…
3. 39 T.C. 362 — Wilson v. Commissioner
   IRCCourt RulingsNov 6, 1962
   Beuge, Judge: Respondent bas determined a deficiency in income tax for the year 1957 in tbe amount of $1,716.50. The primary issue herein is whether the amount paid for an annuity for petitioner by his employer is includable in petitioners’ gross income for the year 1957. The resolution of this issue depends upon (1) w…
4. 54 T.C. 953 — Estate of Benjamin v. Commissioner
   IRCCourt RulingsMay 11, 1970
   …o satisfy the “total distributions payable” requirement of section 402. Respondent reasons that the 1957 assignment of the annuity policies to Benjamin upon termination of the trust constituted a “distribution” of Benjamin’s entire interest in the trust corpus at that time. Thus, respondent argues, the subsequent recei…
5. 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…
6. 44 T.C. 335 — F. & D. Rentals, Inc. v. Commissioner
   IRCCourt RulingsJun 9, 1965
   …rd party whose decision on the disagreement should be final and binding on both parties. On May 24, 1957, the petitioner corporation was organized under the laws of the State of Indiana, with an authorized capital of $50,000 represented by 1,000 shares of the par value of $50 per share. Five hundred of such shares were…
7. 38 T.C. 312 — Hydro Molding Co. v. Commissioner
   IRCCourt RulingsMay 28, 1962
   Scott, Judge: Respondent determined a deficiency in petitioner’s income tax for the calendar year 1957 in the amount of $9,221.42. The only issue for decision is whether petitioner is entitled to a deduction in the year 1957 in the amount of $17,733.51 as a contribution to a profit-sharing plan. FINDINGS OF FACT. Some …
8. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
   IRCCourt RulingsDec 11, 2003★ strong match
   … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
9. 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 (…
10. 38 T.C. 481 — John T. Carson Co. v. Commissioner
    IRCCourt RulingsJun 29, 1962
    OPINION. Fay, Judge: The respondent contends that the petitioner is not entitled to a deduction in 1957 for the contribution made to the profit-sharing trust for the year 1957 because it was paid neither in that year nor within the period prescribed in section 404(a) (6) of the Internal Revenue Code of 1954. Section 40…
11. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980★ strong match
    …payer-corporations were entitled to deduct contributions made to trustees on approximately June 28, 1957, for purposes of employee profit-sharing, where a plan document was not executed until Aug. 30, 1957, fully 2 months after the close of the taxpayers’ fiscal years. The court reasoned that— “The preliminary question…
12. 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))…
13. 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. …
14. 35 T.C. 405 — Coppola v. Commissioner
    IRCCourt RulingsDec 9, 1960
    …dent 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 of * * * $2…
15. 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…
16. 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…
17. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
18. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010
    …h the amount of the loss before she may claim a casualty loss deduction. Clem v. Commissioner, T.C. Memo. 1991-414 (citing Towers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957));
19. 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…
20. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…