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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. 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
   ed do not apply to requests for any documents to the extent § 6104 applies. Statement identifying information to be deleted from public inspection .04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
3. 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…
4. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
   IRCCourt RulingsJan 31, 1973★ strong match
   ave for the following year. Each employee hired after April 1,1964, became entitled to 6 days’ sick leave for his first year and each succeeding year. Any employee who had been employed for 1 year or more as of April 1, 1964, so that his second anniversary date of employment would fall after April 1,1964, would be paid…
5. Treas. Reg. § 1.1563-1(b)(4)(i) — Definition of controlled group of corporations and component members and related concepts.
   IRCRegulationsDec 30, 2024
   …4)(i) (i) Example 1. B, an individual, owns all of the stock of corporations W and X on each day of 1964. W and X each use the calendar year as their taxable year. On January 1, 1964, B also owns all the stock of corporation Y (a fiscal year corporation with a taxable year beginning on July 1, 1964, and ending on June …
6. 62 T.C. 456; 62 T.C. No. 51 — Latrobe Steel Co. v. Commissioner
   IRCCourt RulingsJul 3, 1974
   who were eligible on December 31, 1963, for a regular vacation in 1964, would become entitled to 13 weeks of extended vacation pay on January 1,1964. 2. Fifty percent of all those employees, in order of accumulated continuous service, who were eligible on December 31, 1964, for a regular vacation in 1965, exclusive of…
7. 55 T.C. 1144 — Loevsky v. Commissioner
   IRCCourt RulingsMar 31, 1971
   as filed. They filed joint Federal income tax returns for the taxable years 1964 and 1965 with the district director of internal revenue, Newark, N.J. George Loevsky and Euth Loevsky are husband and wife who resided in Lyndhurst, N. J., when the petition herein was filed. They filed joint Federal income tax returns for…
8. 56 T.C. 263 — Smith v. Comm'r
   IRCCourt RulingsMay 12, 1971
   …nder section 453(d) (1) (A) in return for annuities which had no ascertainable fair market value in 1964, we think that the 1964 deficiency determined against the Smiths may be approved upon the more fundamental ground set forth in the notice of deficiency. See p. 281, supra. In that notice, the Commissioner determined…
9. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
   IRCCourt RulingsMar 6, 2001★ strong match
   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…
10. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997★ strong match
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…
11. 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,…
12. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968
    …ner (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 J. Fleitz an…
13. 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 …
14. 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…
15. 57 T.C. 278 — Richards v. Commissioner
    IRCCourt RulingsNov 24, 1971
    …d hold in trust under this Suspended Plan sufficient assets to equal the amounts which as of July 2,1964, were credited to the accounts of the Bargaining Unit Employees whose names are set forth in Exhibit A hereto attached, together with an amount equal, as of the date of transfer, to the proportionate or pro rata sha…
16. 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))…
17. 71 T.C. 1049 — Minnis v. Commissioner
    IRCCourt RulingsMar 26, 1979
    …tates v. Miroff, 353 F.2d 481 (7th Cir. 1965), and United States v. Sullivan, 333 F.2d 100 (3d Cir. 1964), the Government took the position, diametrically opposed to that taken by respondent herein, that a debtor-creditor relationship existed between the policyholder and the insurance company with the policy simply col…
18. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    …3, 7 (1987); Hays Corp. v. Commissioner , 40 T.C. 436, 442-443 (1963), affd. 331 F.2d 422 (7th Cir. 1964). Our jurisdiction to grant equitable relief is limited. Woods v. Commissioner , 92 T.C. 776, 784-787 (1989); Estate of Rosenberg v. Commissioner , 73 T.C. 1014, 1017-1018 (1980). Accordingly, we must sustain respon…
19. 54 T.C. 1679 — Clarke v. Commissioner
    IRCCourt RulingsAug 31, 1970
    …rs. Charles A. Kuhnmuench (docket No. 486-69) as follows: DooleetNo. TYB Deficiency 342-69_Dec. 31, 1964 $ 884. 01 486-69_Dee. 31, 1964 $4, 235. 48 The only issue is whether distributions from a qualified profit-sharing plan to Miss Marie Clarke and Mr. Charles A. Kuhnmuench in the amounts of $7,261.32 and $21,202.20, …
20. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…