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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. 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 (…
10. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973★ strong match
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
11. 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…
12. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    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…
13. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue 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, 19…
14. 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 …
15. 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…
16. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    …e and will not be considered by the Court. 3 Rule 143(b); Evans v. Commissioner , 48 T.C. 704, 709 (1967), affd. per curiam 413 F.2d 1047 (9th Cir. 1969). The record of this case was closed prior to the submission of the parties' briefs. Accordingly, we hold that the additional facts contained in petitioners' briefs th…
17. 57 T.C. 383 — Willie v. Commissioner
    IRCCourt RulingsDec 16, 1971
    …, Judge: Bespondent determined a deficiency in petitioner’s Federal income tax for the taxable year 1967 in the amount of $105. The only issue for decision is whether the amount received by petitioner during 1967 for participation in the Biloxi Municipal Separate School District inservice program constituted a scholars…
18. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    …etermination letters shall have limited application * * * See also Vernaccini v. Commissioner, T.C. Memo. 1974-66. Some of the cited cases raise the question of the application of secs. 165(a) and 23(p), I.R.C. 1939, to a determination of the proper effective date of trust instruments adopted by accrual basis taxpayers…
19. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023
    … relationship. See Denman v. Commissioner , 48 T.C. 439, 450 (1967); Haeder v. Commissione r , T.C. Memo. 2001- 7 , 2001 Tax Ct. Memo LEXIS 6 ; Shelley v. Commissioner, T.C. Memo. 1994- 432 . In determining whether a person is an employee under the general common law of agency, we consider several nonexclusive factors.…
20. 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 …