| CC-1998-008(PDF, 10K) |
11/19/1998 |
| Fluor v. United States |
| Issue: Whether the taxpayer owes interest under section 6601(a) on the underpayment of its 1982 tax liability, notwithstanding that such underpayment subsequently was eliminated by a carryback, under section 904(c), of excess foreign tax credits from its taxable year 1984. |
| CC-1997-015(PDF, 9K) | 11/19/1998 |
| Clark D. and Janis L. Pulliam v. Commissioner |
| Issue: Whether the distribution to a sole shareholder of the stock of a newly formed corporation qualified under I.R.C. § 355. |
| CC-1998-006(PDF, 7K) | 09/04/1998 |
| Estate of Clara K. Hoover Deceased, Yetta Hoover Bidegain Personal Representative v. Commissioner |
| Issue: Whether the election of special use valuation under I.R.C. § 2032A precludes a valuation that takes into account a minority interest discount under section 2031. |
| CC-1998-005(PDF, 7K) | 09/04/1998 |
| McCormick v. Peterson |
| Issue: Whether the taxpayer was subject to the frivolous return penalty under section 6702. |
| CC-1998-004(PDF, 9K) | 09/04/1998 |
| Barry I. Fredericks v. Commissioner |
| Issue: Whether the Court of Appeals erred in determining that the Service is equitably estopped from relying on a Form 872-A to indefinitely extend the period of limitations when the Service's actions misled the taxpayer into believing that the form was not in effect. |
| CC-1998-003(PDF, 6K) | 07/31/1998 |
| Golden Belt Telephone Cooperative v. Commissioner |
| Issue: Whether billing and collection services performed by a rural telephone cooperative on behalf of long-distance carriers constitute "communication services" as defined in I.R.C. section 501(c)(12)(B). |
| CC-1998-002(PDF, 8K) | 07/31/1998 |
| Paul A. Bilzerian v. United States |
| Issue: Whether issuance of an erroneous refund following taxpayer's payment of the original assessment revives that assessment to permit enforced collection of the amount erroneously refunded. |
| CC-1998-001(PDF, 7K) | 07/31/1998 |
| John D. & Karen Beatty v. Commissioner |
| Issue: Whether the court correctly determined that petitioner was entitled to reduce gross receipts by cost of goods sold to determine gross income? |
| CC-1997-014(PDF, 7K) | 07/31/1998 |
| Transwestern Pipeline Co. v. United States |
| Issue: Whether the cost of recoverable line pack gas, the gas used to charge and operate an interstate natural gas pipeline system, is properly treated as (i) merchandise and thus included in inventory; (ii) a depreciable capital asset; or (iii) a nondepreciable capital asset. |
| CC-1997-013(PDF, 7K) | 07/31/1998 |
| Pacific Enterprises & Subsidiaries v. Commissioner |
| Issue: Whether the cost of recoverable cushion gas and recoverable line pack gas, the gas used to maintain adequate pressure in a gas storage facility and a pipeline, respectively, is properly treated as (i) merchandise and thus included in inventory; (ii) a depreciable capital asset; or (iii) a nondepreciable capital asset. |
| CC-1997-012(PDF, 9K) | 07/31/1998 |
| William R. Jackson v. Commissioner |
| Issue: Whether Termination Payments from an insurance company to a former insurance agent constitute net earnings from self-employment within the meaning of section 1402(a) of the InternalRevenue Code (the Code) so as to be subject to tax under theSelf-Employment Contributions Act (SECA). |
| CC-1997-011(PDF, 8K) | 07/31/1998 |
| Trans City Life Insurance Company v. Commissioner |
| Issue: Whether the Commissioner committed an abuse of discretion in determining that certain reinsurance agreements between unrelated parties had a "significant tax avoidance effect" within the meaning of I.R.C. § 845(b). |
| CC-1997-010(PDF, 5K) | 07/31/1998 |
| Sun Microsystems, Inc. v. Commissioner |
| Issue: Whether the spread income realized from a disqualifying disposition of stock purchased through the taxpayer's incentive stock option ("ISO") plan constitutes wages under section 41(b)(2)(D) in determining whether certain qualified research expenses qualify for the credit for increasing research activities under section 41. |
| CC-1997-009(PDF, 6K) | 07/31/1998 |
| Royal Caribbean Cruises, Ltd. V. United States |
| Issue: Whether I.R.C. § 4471, which imposes a one-excise tax of $3.00 for each passenger who "embarks" or "disembarks" a commercial vessel in the United States, but makes intermediate stops in the United States, where passengers temporarily leave the ship. |
| CC-1997-008(PDF, 8K) | 07/31/1998 |
| The May Department Stores Co. v. United States |
| Issue: Whether interest accrued on the taxpayers' underpayments of tax for 1983 and 1984 from the due date of the first or third estimated tax payment for the next succeeding years. |
| CC-1997-007(PDF, 8K) | 07/31/1998 |
| The Edna Louise Dunn Trust Morgan Guaranty Trust Company Trustee v. Commissioner |
| Issue: Whether a portion of the stock of a subsidiary distributed to petitioner in a spinoff constituted taxable "other property" under I.R.C. § 355(a)(3)(B). |
| CC-1997-006(PDF, 9K) | 07/31/1998 |
| Robert B. Risman & Eleanor Risman v. Commissioner |
| Issue: Whether a remittance forwarded to the Service with a Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, constitutes a payment of tax or a deposit in the nature of a cash bond for purposes of the period of limitations for seeking a refund of such remittance. |
| CC-1997-005(PDF, 7K) | 07/31/1998 |
| Charles E. Hurt v. United States |
| Issue: Whether the Service was entitled to assess and collect statutory interest on the amount of tax and additions to tax embodied in a Tax Court decision that resulted from a settlement agreement entered into by the taxpayers and the Service. |
| CC-1997-004(PDF, 7K) | 07/31/1998 |
| Robert E. & Geneva U. Duncan v. United States |
| Issue: Whether disability benefits paid to taxpayer from the Policemen and Firefighter's Retirement Fund of the Lexington-Fayette Urban County Government can be excluded from gross income under I.R.C. § 104(a)(1) as benefits paid under a statute in the nature of a workmen's compensation act. |
| CC-1997-003(PDF, 4K) | 07/31/1998 |
| Buckeye Countrymark v. Commissioner |
| Issue: Whether section 277 of the Internal Revenue Code applies to nonexempt cooperatives subject to subchapter T of the Code. |
| CC-1997-002(PDF, 9K) | 07/31/1998 |
| United States v. Cheng C. Kao & Susan L. Kao |
| Issue: Can the Service issue summonses to compel a taxpayer tosign consent directives which authorize the release of recordsfrom unidentified domestic and foreign banks, consistent withthe requirements of I.R.C. § 7609? |
| CC-1997-001(PDF, 10K) | 07/31/1998 |
| Xerox Corporation v. United States |
| Issue: Whether, under Article 23(1)(c) of the U.S.-U.K. Income Tax Treaty, a U.S. corporation is entitled to continue to treat U.K. Advance Corporation Tax (ACT) as a creditable tax paid by taxes deemed paid under section 902(a) of the Internal Revenue Code for the year in which the ACT was paid, when the subsidiary subsequently surrenders all or part of the ACT to lower-tier U.K. subsidiaries for use to satisfy their U.K. corporate tax liabilities. |
