Search the Pension Law Library

1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …Supp.). Meanwhile, two successive new editions of the Code of Federal Regulations were published in 1967 and 1968. Each reprinted the 1962 regulations. 26 C.F.R. sec. 1.482-1 (1967); 26 C.F.R. sec. 1.482-1 (1968). The 1967 revision to the Code of Federal Regulations contained regulations promulgated on or before Decemb…
2. 57 T.C. 278 — Richards v. Commissioner
   IRCCourt RulingsNov 24, 1971
   …her pro-rata share of the earnings on his or her Dishursable Portion for the period from January 28,1967, to and including June 30,1967. Section 1.3 The total earnings of the Trust for the fiscal year ended June 30, 1967, less the amount of earnings paid out as provided in the immediately preceding Section 1.2 shall be…
3. 62 T.C. 150; 62 T.C. No. 18 — Farley Funeral Home, Inc. v. Commissioner
   IRCCourt RulingsMay 13, 1974
   … Schimmel, Farley, and Estes carried on the business from 1958 until petitioner was incorporated in 1967. From the date of incorporation, October 9, 1967, continuing through the years in issue, these three persons each owned 33y3 shares of petitioner’s common stock and were officers and directors of petitioner. During …
4. 63 T.C. 11 — Gillis v. Commissioner
   IRCCourt RulingsOct 2, 1974
   …ies received 0 $24,998.84 (2,098.53) Aug. 31,1966 Securities received 0 5,003.30 (7,101.83) Mar. 31,1967 Accrual-receivable 34,498.38 0 27,396.55 May 17,1967 Securities received 0 3,159.88 24,236.67 Dec. 20,1967 Securities received 0 5,694.65 18,542.02 Mar. 31,1968 Accrual-receivable 36,044.15 . 0 54,586.17 Mar. 31,196…
5. 63 T.C. 255; 1 Employee Benefits Cas. (BNA) 1135 — Harwood Associates, Inc. v. Commissioner
   IRCCourt RulingsNov 26, 1974
   zation payment 1967 _ $100 8/18/67 8/31/67 1,900 11/15/67 1968 _ 2,000 8/8/68 10/7/68 1969 ^_ 1,000 8/22/69 8/29/69 1970 _ 9,000 (Undisclosed) 8/31/70 By a letter dated October 25, 1967, petitioner’s authorized representative requested that the district director of internal revenue, Buffalo, N.Y., issue a determination…
6. 61 T.C. 727; 61 T.C. No. 78 — Robertson v. Commissioner
   IRCCourt RulingsMar 13, 1974
   …eficiencies in Federal income taxes of the petitioners as follows: Docket No. Year Amount 3088-71__ 1967 $3, 283. 98 3089-71_ 1967 2,438.55 3090-71_ 1967 3, 105. 26 3205-71_ 1967 1, 957. 53 Upon joint motion by the parties, these cases were consolidated for trial, briefs, and opinion. Certain concessions have been made…
7. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
   IRCCourt RulingsMay 26, 1976
   …t determined the following deficiencies in petitioner’s Federal income taxes: TYEAPR.30— Deficiency 1967_ $168,077.53 1968_ 156,568.00 Two issues require consideration: (1) Whether a downward adjustment should be made to the foreign tax credit claimed by petitioner for the taxable year ended April 30, 1967, and (2) whe…
8. 68 T.C. 929 — Jobusch v. Commissioner
   IRCCourt RulingsSep 19, 1977
   …ers in the firm. With these ideas in mind, Friedman and Jobusch caused the Corporation, on June 14, 1967, to adopt a stock bonus plan and enter into an agreement with Friedman, Jobusch, and Richard E. Mc-Clanahan, one of Corporation’s senior employees, as trustees, for the creation of a stock bonus trust under the plan…
9. 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)…
10. 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…
11. 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. …
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. 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 (…
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. 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…
16. 58 T.C. 940 — Funkhouser v. Commissioner
    IRCCourt RulingsSep 11, 1972
    …nts as follows: Calendar year Amount Calendar year Atnount 1964 _$89. 50 1966_103. 00 1965 _ 87. 47 1967 _109.25 Respondent determined deficiencies in the Federal income taxes of petitioners Arthur D. Burnett (hereinafter referred to as Burnett) and Anne B. Burnett for the years and in the amounts as follows: Calendar …
17. 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…
18. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968
    . 7, 1956), affirming a Memorandum Opinion of this Court; Hagen Advertising Displays, Inc., 47 T.C. 139, 146 (1966), on appeal (C.A. 6, Apr. 3, 1967). 2. Advance Receipts. — Petitioner argues in the alternative that if the $1,250,000 does not constitute a loan, it represents advance payments which need not be reported …
19. 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 .…
20. 24 T.C. 460 — Northwest Automatic Products Corp. v. United States
    IRCCourt RulingsJun 23, 1955related by meaning
    h respect to this matter is hereby set for_ at_if that time is not convenient, kindly advise us promptly in order that a continuance may- be arranged. This notice, sent by registered mail, constitutes commencement of the renegotiation proceedings in conformity with the provisions of subsection (c) (1) of the Renegotiat…