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61 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …d. Reg. 3597- 3598 (Apr. 14, 1962), 1962-1 C.B. 43, 49- 51, reprinted in 26 C.F.R. sec. 1.482-1(b) (1961 ed. 1965 Cum. Supp.). We will di scuss the substance of the 1962 regulations shortly. 120 BB. The creation of a new title of the Code of Federal Regulations In 1961 the Government Printing Office issued a new title …
  2. 46 T.C. 431 — John C. Nordt Co. v. Commissioner
    IRCCourt RulingsJun 24, 1966
    …Inc_. John C. Nordt Co., Inc.. John C. Nordt Co., Inc_. Bertha C. Nordt_ Frieda C. Nordt_ 1959 1960 1961 1961 1961 $538.79 2,084.23 1,500.00 160.76 228.18 In docket No. 1153-65, Bertha claims an overpayment for 1961 instead of a deficiency. Three issues are involved: 1. Did the respondent err in disallowing $1,846.32 o…
  3. 48 T.C. 75 — Pepsi-Cola Niagara Bottling Corp. v. Commissioner
    IRCCourt RulingsApr 26, 1967
    …orporate affairs, including the hiring and firing of all employees. His salary was $28,000 for both 1961 and 1962 and $30,000 for 1963. Peter P. Seereiter served as vice president of petitioner from July 9, 1962, through December 31, 1963. His duties, both before and after assuming the executive position, involved supe…
  4. 54 T.C. 953 — Estate of Benjamin v. Commissioner
    IRCCourt RulingsMay 11, 1970
    …: Respondent determined a deficiency of $9,838.18 in the income tax of petitioners for taxable year 1961. The issues presented for decision are (1) whether petitioners are entitled to capital gains treatment upon the surrender of an annuity policy and receipt of the balance payable in a lump sum (under section 402 or s…
  5. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973★ strong match
    …ude v. Commissioner, 372 U.S. 128 (1963), American Automobile Assn. v. United States, 367 U.S. 687 (1961), and Commissioner v. Milwaukee & Suburban Transport Corp., 367 U.S. 906 (1961), which require a decision against the taxpayer herein. While it is true that the Schlude and American Automobile eases were concerned w…
  6. 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,…
  7. 42 T.C. 299 — Sherwood Swan & Co. v. Commissioner
    IRCCourt RulingsApr 30, 1964
    fiscal years 1959, 1960, and 1961, the amounts of petitioner’s assets contained in the profit-sharing trust account of Sherwood Swan were as follows: Trust account balance of Sherwood Swan Sherwood Swan’s percent age of total beneficiaries’ equities Fiscal year $62,546.14 45.65 1959. 66,314.87 54.92 1960. 69,662.04 54…
  8. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    ciency, id. , petitioner cites Chrysler Corp. v. Brown , 441 U.S. 281 (1979), for the proposition that respondent’s reopening procedures in Rev. Proc. 94-68, 1994-2 C.B. 803, should have “the force and effect of law”. Chrysler Corp. v. Brown , 441 U.S. at 302 (quoting Morton v. Ruiz , 415 U.S. 199, 232, 235, 236 (1974)…
  9. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  10. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984
    … view, not organizations described in section 501(c)(3). See S. Rept. 730, 87th Cong., 1st Sess. 2 (1961), 1961-2 C.B. 466, 467. See also Rev. Rui. 60-384, 1960-2 C.B. 172. As a result, in 1961, Congress amended section 403(b) (see Pub. L. 87-370, 75 Stat. 796, 801) to permit annuity contracts purchased for public scho…
  11. 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 (…
  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. 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…
  14. 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…
  15. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968
    …tipulated and they are so found. Ed & Jim Fleit,z, Inc., an Ohio corporation, formed on J anuary 3, 1961, had its principal office in Oregon, Ohio, at the time its petition was filed. The legal residences of the individual petitioners at the time their petitions were filed were Oregon, Ohio, for Edward B. and Thelma Fl…
  16. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10066-93. Filed October 3, 1995. Harold L. Humberson, pro se. Alan R. Pere…
  17. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    …reply brief includes 4-½ pages of objections to respondent's proposed findings of fact. Id . I. The Memorandum Opinion In T.C. Memo. 1995-492, filed October 11, 1995, the Court decided the present case. In our memorandum opinion, we rejected petitioners' argument that petitioner's Transfer Refund had not been received …
  18. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    …sed here. Estate of Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985), affg. on this issue T.C. Memo. 1984-674, 49 T.C.M. 331, 53 P-H Memo T.C. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; Fir…
  19. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  20. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    …red by the Joint Committee on Taxation (the Blue Book); privatd letter rulings and technical advice memoranda issued after October 31, 1976; actions on decisions and general counsel memoranda issued after March 12, 1981 (as well as general counsel memoranda published in pre-1955 volumes of the Cumulative Bulletin); Int…