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1. 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
   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…
2. 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…
3. 64 T.C. 901 — Precision Industries, Inc. v. Commissioner
   IRCCourt RulingsAug 19, 1975
   …ffective in 1969 and 1970, unless otherwise indicated. See also Subscription Television, Inc., T.C. Memo. 1974-107; Misceramic Tile, Inc., T.C. Memo. 1968-31. Compare Aero Rental, 64 T.C. 331 (1975). See Subscription Television, Inc., supra.
4. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   … and June 30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M. (CCH) 1707 (a case involving tax years 1979, 1980, and 1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d 825 (5th Cir. 1996) In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
5. 66 T.C. 324 — Bianchi v. Commissioner
   IRCCourt RulingsMay 20, 1976
   70. On November 30, 1970, the corporation deposited the sum of $16,993.41 in the trust account at Bankers Trust Co. for the pension plan contribution. On February 18, 1971, the corporation filed its initial income tax return (Form 1120-S, U.S. Small Business Corporation Income Tax Return) for the taxable year November …
6. 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 (…
7. 72 T.C. 377 — La Mastro v. Commissioner
   IRCCourt RulingsMay 23, 1979
   …nitial fiscal year of the corporation was a short taxable period of 14 days commencing November 20, 1970, and ending December 3,1970. The reason for the adoption of the initial short taxable year was to obtain two pension plan contributions by petitioner’s corporation prior to the application of the 1969 Tax Reform Act…
8. PLR 200610016 — Year of Deduction
   IRCPrivate Letter RulingsMar 10, 2006related by meaning
   … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
9. 69 T.C. 773 — Lansons, Inc. v. Commissioner
   IRCCourt RulingsFeb 27, 1978
   …tion exceeded $10,000 for a particular year. Thus respondent would include Morris J. Kochman (1969, 1970, and 1971), Henry Gottheil (1969 and 1970), Owen G. Parr (1970), and Marvin Armband (1970 and 1971) in the prohibited group. On this basis, of the participating employees for the 3 fiscal years, 67 percent, 75 perce…
10. 68 T.C. 929 — Jobusch v. Commissioner
    IRCCourt RulingsSep 19, 1977
    …0,000 check — Corporation made interest payments to the Trust on April 20, 1969, and on February 9, 1970. Through a second arrangement with Jack Sarver, Corporation acquired an interest in a project alternatively referred to as University Inns, Inc., or Hotels, Ltd. (hereinafter Hotels). On February 4, 1970, Friedman a…
11. 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…
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. 64 T.C. 331 — Aero Rental v. Commissioner
    IRCCourt RulingsMay 29, 1975
    … in order to enable it to qualify under section 401 could be made applicable retroactively. In June 1970, Aero submitted to the District Director of Internal Revenue, Phoenix, Ariz., an application for a determination that the plan qualified under section 401. T. M. Hoxie, as president of Aero, signed the application. …
14. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
15. 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…
16. 69 T.C. 97 — Feroleto Steel Co. v. Commissioner
    IRCCourt RulingsOct 25, 1977
    to: Date of Repayments of Payments of repayment principal interest Dec. 1969.0 $2,656 Dec. 1970.0 10,625 Dec. 28, 1971 .$125,000 10,625 125,000 23,906 Late in 1971 the trustees asked Mr. Smith to ascertain from Seaboard the amount of repayment of the loan and the possibility of repaying the loan over a period of four q…
17. 63 T.C. 386 — Estate of Stefanowski v. Commissioner
    IRCCourt RulingsDec 19, 1974
    …ation by a large majority of employees was a major cause leading to this decision. On September 18, 1970, Kroger’s board of directors resolved that “The Kroger Co. Employees’ Savings and Profit Sharing Plan shall be terminated as of January 2, 1971,l! in accordance with Sections 12 and 14 of the Plan.” Also on Septembe…
18. 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,…
19. 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))…
20. 78 T.C. 1187; 78 T.C. No. 83 — Plastic Engineering & Mfg. Co. v. Commissioner
    IRCCourt RulingsJun 30, 1982
    …axable year. In Bianchi, the taxpayer therein formed a professional service corporation on Nov. 23, 1970, which subsequently elected to be taxed as a small business corporation under subch. S of the Code. The corporation adoptee) an employees’ pension plan on Nov. 24, 1970, effective Nov. 30, 1970. The corporation depo…