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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   t ions on allocations of income under section 482 of the Internal Revenue Code of 1954. The 1969 revision to the Code of Federal Regulations contained regulations promulgated on or before December 31, 1968. See 26 (p art 1 (secs. 1.401-1.500)) C.F.R. v ( 1969). Included in the 1969 revision was section 1.482-1, which c…
2. 64 T.C. 331 — Aero Rental v. Commissioner
   IRCCourt RulingsMay 29, 1975
   reason during 1969 or 1970. As a result, no distributions were made from the plan during those years. The first terminations did not occur until 1973. Based on its contributions to the plan, Aero deducted $15,000 for 1969 and $18,313.49 for 1970. In his notice of deficiency, the Commissioner disallowed those deductions…
3. 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…
4. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
   IRCCourt RulingsNov 15, 2004
   those who thus misused the private foundations. See H. Rept. 91-413 (Part 1), 4, 20-21 (1969), 1969-3 C.B 202, 214; S. Rept. 91-552, 6, 28-29 (1969), 1969-3 C.B. 426, 442-443; also see Staff of the Joint Committee on Internal Revenue Taxation, General Explanation of the Tax Reform Act of 1969 (hereinafter sometimes re…
5. 63 T.C. 621 — Packard v. Commissioner
   IRCCourt RulingsMar 11, 1975
   …come tax: Docket No. Petitioner Year Deficiency 524-73 Ronald C. Packard and 1968 Roma Jean Packard 1969 $696 806 525-73 Floyd L. Packard and 1968 Alice E. Packard 1969 618 760 526-73 H. Von Packard 1968 305 Sheila D. Packard 1968 308 H. Von Packard and Sheila D. Packard 1969 626 The' sole issue presented for decision …
6. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
   IRCCourt RulingsMay 30, 1984
   …de to make an application for exemption mandatory for most organizations organized after October 9, 1969. As the House report clearly stated— Under present law, an organization is exempt under section 501(c)(3) of the code if it meets the requirements of that provision. Although many organizations apply to the Internal…
7. 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)…
8. 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 (…
9. 71 T.C. 765 — Elliot Knitwear Profit Sharing Plan v. Commissioner
   IRCCourt RulingsFeb 12, 1979
   …lied to qualified profit sharing plans, too. H. Rept. 91-413 (Part 1), 91st Cong., 1st Sess. 46-47 (1969), 1969-3 C.B. 200, 230; S. Rept. 91-552, 91st Cong., 1st Sess. 67 (1969), 1969-3 C.B. 423, 467. See S. Rept. 1622, 83d Cong., 2d Sess. 313 (1954); Rowley United Pension Fund v. Commissioner, 64 T.C. 343 (1975). See …
10. 70 T.C. 139 — Ziegler v. Commissioner
    IRCCourt RulingsMay 2, 1978
    … to and paid the penalty prescribed by section 72(m)(5)(B) for such distributions. From January 24, 1969, to December 1969, the petitioner did not participate in any qualified retirement plan. In December 1969, the partnership signed a joinder to the master plan maintained by Pittsburgh National Bank and thereby establ…
11. 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))…
12. 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…
13. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    IRCCourt RulingsJan 26, 1984
    …avorable tax treatment than compensation that was paid currently. Thus, under the Tax Reform Act of 1969, capital gains treatment was limited to only that portion of a lump-sum distribution attributable to contributions made before 1970. Thus, Congress itself made the tax treatment dependent upon the time of the contri…
14. 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…
15. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    … 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).
16. 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 .…
17. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    tion to be carried out with respect to whether the tax imposed by section 4975 of Title 26 should be applied to any person referred to in the request. Because our Rules do not recognize a motion to limit a deficiency determination, petitioners’ request should have been cast as a motion for partial summary judgment unde…
18. 63 T.C. 267 — Cohen v. Commissioner
    IRCCourt RulingsNov 26, 1974
    …mployees, plus the fund balance as of the date the unfunded liability is determined. As of June 30, 1969, the fund balance was $20.6 billion. On that date the unfunded liability was $57.7 billion. As of June 30, 1969, total aggregate section 8334 deductions, voluntary contributions, and service credit payments from the…
19. 74 T.C. 1029 — E. F. Higgins & Co. v. Commissioner
    IRCCourt RulingsAug 11, 1980
    … T.C. 621 (1974), affd. 518 F.2d 554 (8th Cir. 1975); Peter F. Mitchell Corp. v. Commissioner, T.C. Memo. 1968-209, supplemental opinion, T.C. Memo. 1969-73. The District Court in Container Service Co. v. United States, congently stated: In enacting the qualification requirements for pension plans under Section 401 the…
20. 64 T.C. 621 — Richardson v. Commissioner
    IRCCourt RulingsJul 23, 1975
    …mined deficiencies in the amounts of $4,064.47 and $6,635.62 in petitioners’ Federal income tax for 1969 and 1970, respectively. The issues for decision are: (1) Whether funds placed in trust by petitioner Gale R. Richardson’s employer during 1969 and 1970 were properly taxable to petitioners during those years. The re…