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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. 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…
3. 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 …
4. 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…
5. 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…
6. 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…
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. 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…
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. 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…
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. 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. 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…
14. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972★ strong match
    …. 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 CONTRACTS. (m) Special Rules Applicable to Employee Annuities and Distributions undeb Employee Plan…
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. 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 …
17. 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…
18. 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…
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. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    performed by anyone else. Discussion Petitioners bear the burden of establishing that respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a); Welch v. Helvering , 290 U.S. 111 (1933). Petitioners' briefs refer to several facts which were not included…