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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …eanwhile, 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 December 31, 19…
2. 63 T.C. 621 — Packard v. Commissioner
   IRCCourt RulingsMar 11, 1975
   st 1, 1968, the partnership supplied all equipment, uniforms, bookkeeping, and billing; after August 1,1968, the corporation provided all these items. The parties have stipulated that prior to August 1, 1968, the receptionist and the dental assistants were supervised by a general manager who was in turn supervised by t…
3. 70 T.C. 788 — 212 Corp. v. Commissioner
   IRCCourt RulingsAug 31, 1978
   …ollowing deficiencies in the petitioners’ Federal income taxes: Docket No. Year Deficiency 8683-74 .1968 $334.00 1969 667.00 8684-74 .1968 1,709.49 1969 3,488.97 By an amendment to his answer, the Commissioner claimed increased deficiencies as follows: Docket No. Year Deficiency 8683-74 .1968 $714.00 1969 1,429.00 8684…
4. 63 T.C. 11 — Gillis v. Commissioner
   IRCCourt RulingsOct 2, 1974
   …ng plan for those employees continuing to work for it after the closing date. On or about August 5, 1968, B-G remitted $36,044.15 (plus interest not herein material) to Marine Midland Trust Co. of Rochester, N.Y., which had previously qualified as successor trustee of the B-G plan. This sum represented the entire amoun…
5. 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,…
6. 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…
7. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
   IRCCourt RulingsOct 3, 1989related by meaning
   … 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.S. 841 (1969).
8. 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))…
9. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
   IRCCourt RulingsJun 3, 1998related by meaning
   …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. 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)…
11. 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 …
12. 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…
13. 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…
14. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    xcise tax returns could have concluded that the relevant transfer was not a prohibited transaction, or, if it was, that it had been corrected earlier. We have carefully considered all remaining arguments made by the parties for holdings contrary to those expressed herein, and, to the extent not discussed above, find th…
15. 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. …
16. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…
17. 91 FR 55462 — Federal Independent Dispute Resolution Operations; Correction
    IRCFinal Rules (FR)Aug 28, 2026related by meaning
    on, Publications and Regulations, Associate Chief Counsel, (Procedure and Administration) Department of the Treasury. In concurrence: Kurt D. Dykstra, General Counsel, Office of Personnel Management. [FR Doc. 2026-17622 Filed 8-27-26; 8:45 am] BILLING CODE 6325-63-P; 4831-GV-P; 4510-29-P; 4169-69-P
18. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    …sed here. Estate of Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985), affg. on this issue T.C. Memo. 1984-674, 49 T.C.M. 331, 53 P-H Memo T.C. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; Fir…
19. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
20. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    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’ …