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Go to T.C. Memo. 1969-73 (not yet in the library — opens the official source)
58 documents · 0.54sAllIRCERISAPBGCJoint Board
  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. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related by meaning
    or documents to which § 6104 (document open to public inspection) applies, as described in section 10.03. Taxpayer may protest deletions not made .05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
  3. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
  4. 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…
  5. 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…
  6. 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 …
  7. 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…
  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. 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 …
  10. 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 …
  11. 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…
  12. 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…
  13. 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,…
  14. 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…
  15. 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))…
  16. 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).
  17. 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…
  18. 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…
  19. 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…
  20. 70 T.C. 788 — 212 Corp. v. Commissioner
    IRCCourt RulingsAug 31, 1978
    …ciencies 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 8684-74 .1968 2,1…