IRCCourt RulingsFeb 9, 2023related by meaning
… 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…
IRCCourt RulingsAug 24, 2000
…ing of documents required to be filed. All of the above
documents were dated and notarized July 22, 1982. Even though
these documents were notarized, petitioners claim, and respondent
does not dispute, that these documents were actually executed
after September 3, 1982.
E. Transactions After September 3, 1982
In the St…
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…
IRCCourt RulingsSep 25, 1996
eductions of Partnership Loss
On their individual income tax return for 1982, the Bealors
reported a loss of $80,915, representing their 3.252-percent share of MIT 82's partnership loss. James Cameron reported the
same amount as his 3.252-percent share of those losses in his
1982 Federal income tax return. Frank Pettis…
IRCCourt RulingsDec 11, 1997
…til they were terminated on December 31,
1991, and January 31, 1992, respectively.
- 4 -
On June 4, 1982, petitioner borrowed $130,000 from the
Hickman corporation profit-sharing plan (1982 plan loan). That
loan, which was unsecured, was evidenced by a note payable to
that plan and signed by petitioner (1982 note). The…
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 (…
IRCCourt RulingsAug 25, 1997★ strong match
…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 …
IRCCourt RulingsDec 19, 2000★ strong match
…6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice of deficiency was not an
affected items notice of deficiency. Petitioners assert that the
period of limitation for assessment under TEFRA is inapplicable.
We disagree with petitioners’ ar…
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…
IRCCourt RulingsMar 5, 1987★ strong match
…rict of Columbia for the purpose of appointing independent counsel); 28 U.S.C. sec. 134(b) and (c) (1982) (duty to reside within district to which appointed and duty to reside near courthouse); 28 U.S.C. sec. 137 (1982) (division of duties among the judges of a district); 28 U.S.C. sec. 140(a) (1982) (power to adjourn …
Ann. 2006-45 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba… IRCAnnouncementsJul 31, 2006
…ond James & Associates, Inc. 880 Carillon Parkway P.O. Box 12749 St. Petersburg, FL 33733-2749 4/26/1982
188. Raymond James & Associates, Inc. 880 Carillon Parkway P.O. Box 12749 St. Petersburg, FL 33733-2749 3/8/1982
189. RBC Dain Rauscher, Inc. Dain Rauscher Plaza 60 South Sixth Street Minneapolis, MN 55402-4422 3/2/…
IRCCourt RulingsAug 4, 1983
…ies); Moore v. Commissioner, 71 T.C. 533 (1979) (retail grocery store); Black v. Commissioner, T.C. Memo. 1983-245 (sales of developed real estate); Pilkington v. Commissioner, T.C. Memo. 1983-111 (operation of lounge); Smith v. Commissioner, T.C. Memo. 1983-93 (paint contracting business); Nelson v. Commissioner, T.C.…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999
… from petitioner.
Edgar Murray III (Murray) was a representative of Travelers. From January to June 1982, Murray and the pension committee met
several times to discuss the program. Petitioner introduced
- 6 -
Player to Murray in the spring of 1982.
Andrew Fantasia (Fantasia) was the certified public
accountant for the …
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…8/01/1981
10/01/1981
10.25
10/01/1981
11/01/1981
10.50
11/01/1981
12/01/1981
10.75
12/01/1981
01/01/1982
11.00
01/01/1982
02/01/1982
10.50
02/01/1982
03/01/1982
10.75
03/01/1982
06/01/1982
11.00
06/01/1982
08/01/1982
10.75
08/01/1982
10/01/1982
11.00
10/01/1982
11/01/1982
10.75
11/01/1982
12/01/1982
10.50
12/01/1982
01…
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…
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,…
IRCCourt RulingsAug 13, 1990related by meaning
…C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on proh…
IRCRegulationsSep 9, 2016
…ng to nonvested participants). Thereafter, he does not complete a year of service. As of January 1, 1982, in computing his period of service under the plan his service prior to December 31, 1981, is not required to be taken into account for purposes of section 410(a)(1) and § 1.410 (a)-3. Example 2.The employee in exam…
Ann. 2005-59 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba… IRCAnnouncementsSep 12, 2005
…L 60603 3/11/1986
34. Burton J. Vincent, Chesley & Co. 105 West Adams Street
Chicago, IL 60603 3/25/1982
35. Butler Wick & Co., Inc. City Center One Bldg.
Youngstown, OH 44501 10/8/1992
36. BUYandHold Securities Corporation 110 Wall Street
New York, NY 10005 10/5/2000
37. Carolina Securities Corp. 239 Fayetteville St. …
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…