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 RulingsSep 18, 1996★ strong match
…osition, respondent relies heavily on the fact that petitioner did not use any sick leave in either 1989 or
1990. However, it was not unusual for petitioner to use annual
leave in lieu of sick leave, as evidenced by the fact that
petitioner used annual leave for his knee replacement surgery in
August 1990 and for the c…
T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner IRCCourt RulingsJun 17, 1998
…10,
1988, the IRS published temporary guidance to taxpayers for
transfers occurring after April 30, 1989, that would be subject to section 7520. Notice 89-24, 1989-1 C.B. 660, published on
March 6, 1989, sets forth the formulas for computing the present
value of an annuity on the basis of the appropriate applicable
Fed…
IRCCourt RulingsOct 29, 2002
ing in 1989. The NYSL did not
offer petitioner the option of receiving a lump-sum payment in
1989. Petitioner was employed by the Consulate General of Nigeria when he won the lottery. He used the cash method of
accounting in 1989.
Petitioner received two or three offers to buy the rights to
his future lottery winnings …
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))…
IRCCourt RulingsAug 15, 1994
…est was signed by Samuel J. Sirota, an attorney and a certified public accountant, on September 15, 1989. On September 15, 1989, the corporation timely filed its Federal income tax return, Form 1120S, for its taxable year ended June 30, 1989. The corporation did not claim a deduction for the contributions, if any, it m…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…executive compensation of CEO's
by industry categories as of May 1990, showing results for the
year 1989 classified under all industries and categories of
industries for companies that had sales of approximately $162
million:
Title
Year
Sales
Average
+1 SD
+2 SDs
All Industries
CEO 1989 $162.416 $340.72 $497.96 $655.21…
IRCCourt RulingsSep 25, 1996
…61 F.2d 494 (7th Cir. 1988),
affd. sub nom. Ratliff v. Commissioner
, 865 F.2d 97 (6th Cir.
- 125 -
1989), affd. sub nom. Kirchman v. Commissioner
, 862 F.2d 1486
(11th Cir. 1989), Killingsworth v. Commissioner
, 864 F.2d 1214
(5th Cir. 1989); affd. sub nom. Keane v. Commissioner
, 865 F.2d
1088 (9th Cir. 1989), affd. …
109 T.C. No. 21 — Lakewood Associates; Robert G. Moore, Tax Matters Partner v. Commissioner IRCCourt RulingsDec 29, 1997
… of the property pursuant to the 1989
Manual.
- 7 -
In November 1989, the Corps also entered into a Memorandum
of Agreement (MOA) with the EPA that establishes the procedures
to be used by the Corps staff in reviewing section 67(a) (section
404) CWA permit applications. Specifically, the MOA articulated
IRCCourt RulingsNov 2, 1998
… findings of
fact and opinion with respect to each issue.
Issue 1. Statutory Period of Limitations--1989
Petitioner asserts that he timely filed a 1989 tax return and
therefore maintains that the period for assessing a deficiency and
additions to tax against him for 1989 expired before the date on
which respondent mail…
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 …
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,…
ERISACourt RulingsJan 20, 1998
…g annual
rates were applicable during the course of this transaction:
December 1988, 8.40%; January 1989, 9.01%; February, 9.30%; March,
9.30%; April, 9.62%; May, 9.82%; June, 9.39%; July, 8.86%; August,
8.34%; September, 8.07%; and October, 8.45%. The average annual
rate over this period was 8.96%. This is the rate I …
IRCCourt RulingsOct 17, 1995
…ns of
petitioners herein. Lerch v. Commissioner
, 877 F.2d 624, 631-632
(7th Cir. 1989), affg. T.C. Memo. 1987-295; Geiger v.
Commissioner
, 440 F.2d 688, 689-690 (9th Cir. 1971), affg. per
curiam T.C. Memo. 1969-159. The determination of respondent is
sustained as to rental expenses claimed in 1989 and 1990.
Issue 7. …
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 …
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…0
04/01/1988
06/01/1988
7.75
06/01/1988
09/01/1988
8.00
09/01/1988
11/01/1988
8.25
11/01/1988
04/01/1989
7.75
04/01/1989
06/01/1989
8.00
06/01/1989
08/01/1989
7.75
08/01/1989
09/01/1989
7.50
09/01/1989
10/01/1989
7.25
10/01/1989
12/01/1989
7.50
12/01/1989
03/01/1990
7.25
03/01/1990
06/01/1990
7.50
06/01/1990
07/01/1990…
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…
IRCCourt RulingsDec 19, 1989related by meaning
…cy was correctly determined by the Commissioner.
Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of the parties. Petitioners presented their revised trial mem…
IRCCourt RulingsOct 25, 2012
…spondent issued a favorable determination letter. The plan was amended and
restated on November 18, 1989 (1989 plan), effective for the fiscal year beginning
July 1, 1989. The 1989 plan was amended on June 23, 1997, and June 5, 1998.
On September 13, 2001, the 1989 plan was amended and restated (2001 plan).
The 1989 pl…
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 (…