IRCCourt RulingsFeb 9, 2023related by meaning
… 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…
48 T.C. 75 — Pepsi-Cola Niagara Bottling Corp. v. Commissioner IRCCourt RulingsApr 26, 1967
…e 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 supervising the work of sales pers…
IRCCourt RulingsApr 20, 1970
…surance & Trust Co. Petitioner was an employee of General Controls from November 7, 1940, to May 15,1963, and thereafter was an employee of ITT General Controls, Inc., until it was liquidated in 1964. Petitioner was still in the employ of ITT at the time of trial.
Petitioner was a member of the plan from December of 19…
IRCCourt RulingsJan 27, 1969
…termined a deficiency of $443 in petitioners’ income taxes for the taxable year ending December 31, 1963. The sole issue is whether petitioner is entitled to a deduction of $1,200, half the cost of section 405 retirement plan bonds purchased in that year.
All of the facts have been stipulated and are found accordingly.…
IRCCourt RulingsDec 8, 1969
…yable to his beneficiary if application therefor is made within 1 year of the date of death. During 1963, the petitioner employed five full-time union employees for the entire year; Powell, Kamine, Eeno, Warmouth, and Scholl. Compensation paid them for that year was: $9,999.12, $10,239.13, $10,330.30, $9,635.93, and $9…
Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione… IRCRevenue ProceduresJan 2, 2013related by meaning
or documents to which § 6104 (document open to public inspection) applies, as described in section 10.03.
Taxpayer may protest deletions not made
.05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and … IRCRevenue ProceduresJan 2, 2014related by meaning
, or documents to which §6104 (document open to public inspection) applies, as described in section 10.03.
Taxpayer may protest deletions not made
.05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
IRCCourt RulingsMay 27, 1968
… No. Petitioner (s) FYE Nov. 30-Income tax deficiency
1962 $1,349.51
3564-66 Ed & Jim Fleitz, Inc.. 1963 339.75
1964 None
3565-66 Edward B. Fleitz and Thelma Fleitz. 1962 1963 945.13 657.33
5101-67 Edward B. Fleitz and Thelma Fleitz. 1964 1,050.31
3566-66 James J. Fleitz and Evelyn M. Fleitz. 1963 557.58
5102-67 James …
IRCCourt RulingsMar 6, 2001★ strong match
…v. United States
, 421 F.2d 475 (6th
Cir. 1970); Geurkink v. United States
, 354 F.2d 629 (7th Cir.
1965); Luhring v. Glotzbach
, 304 F.2d 560 (4th Cir. 1962);
Collins v. Commissioner
, supra
; Notaro v. United States
, 71 AFTR
2d 93-659, 93-1 USTC par. 50,030 (N.D. Ill. 1992); First Fed.
Sav. & Loan Association v. Gol…
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,…
IRCCourt RulingsJul 3, 1974
…ng on years of service. The 1962 agreement between petitioner and the union was amended on July 31, 1963, and on October 29, 1963. The purpose of the October 29, 1963, amendment was to adopt a vacation plan that provided for both regular and extended vacation benefits. The 1962 agreement as amended on July 31, 1963, an…
IRCCourt RulingsMay 27, 1969
…uld have assumed the policies only by applying the accumulated vested interest as shown on June 20, 1963, to the premiums due on such policies. He argues that his vested interest should have been calculated as of December 20, 1963, rather than June 20, 1963, because Buensod paid premiums to December 20, 1963, and he re…
IRCRegulationsDec 19, 2016
(b) (b) Returns with respect to payments made in calendar years before 1963 and to certain payments by cooperatives after 1962. In the case of each failure to file a statement, with respect to a payment to another person, required under authority of—
(b)(1) (1) Section 6041, relating to information returns with respect…
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))…
IRCCourt RulingsOct 3, 1989related by meaning
…for taxable years beginning after Dec. 31, 1986.
H. Rept. 1447 at 428, 87th Cong., 2d Sess. at 428 (1962), 1962-3 C.B. 405, 423; S. Rept. 1881, 87th Cong. 2d Sess. at 169 (1962), 1962-3 C.B. 707, 731. Cf. Sanford v. Commissioner, 50 T.C. 823, 826 (1968), affd. per curiam 412 F. 2d 201 (2d Cir. 1969), cert. denied 396 U…
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…
IRCCourt RulingsOct 12, 1978related by meaning
do not deal with the operations of the plan, there is a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comm…
IRCCourt RulingsApr 25, 1972related by meaning
… 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, 1964.
1966 deduction for contributions disallowed.
SBC. 72. annuities ; CERTAIN PROCEEDS OE ENDOWMENT AND LIFE INSURANCE CONTR…
IRCCourt RulingsAug 12, 1998
…rican
Institute of Banking. Additionally, he attended a 2-week course
each year during 1961 through 1963 offered by Pacific Coast Bank
School in Seattle, Washington.
- 3 -
Mr. Shedd served as a loan officer, specializing in real
estate financing, for First National from 1952 until 1963.
During 1963, he left First Natio…
IRCCourt RulingsMay 5, 2008
…, petitioner resided in Illinois .
Petitioner married Christopher Casula (Mr . Casula) on April
23, 1963 . On the day of the trial--April 23, 2007--petitioner
and Mr . Casula (the Casulas) were celebrating their 44th wedding
anniversary .
From 1963 through 1983, Mr . Casula worked for Montgomery
Ward . During this time…