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Thor Power Tool Company v. Commissioner, 439 U.S. 522 (1979), was a United States Supreme Court case in which the Court upheld IRS regulations limiting how taxpayers could write down inventory.
The IRS does have the option of redacting the text of a private ruling and issuing it as a revenue ruling, which may become binding on all taxpayers and the IRS. "Even if it is clear that the taxpayer did not rely on a revenue ruling, courts will often hold the Service to the position expressed in the revenue ruling." [4]
The interpretation that the Internal Revenue Service (IRS, the agency that handles federal taxation) has for this is described in Revenue Ruling 99-40 of the Internal Revenue Manual, that uses the term "use of money". [2] The corresponding statutory guidance is in Section 6601(a) of the Internal Revenue Code. [3] [4] [5]
The Internal Revenue Bulletin (also known as the IRB), [1] [2] is a weekly publication of the U.S. Internal Revenue Service that announces "official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest."
IRS guidance consists of: Revenue Rulings, Revenue Procedures, and various IRS pronouncements applicable to all taxpayers and published in the Internal Revenue Bulletin, [111] which are binding on the IRS; Private letter rulings on specific issues, applicable only to the taxpayer who applied for the ruling
The Board of Tax Appeals found that the money was taxable to the receiver in 1916. On appeal, the Circuit Court of Appeals held that the profits were taxable to the company as income in 1917. North American Oil appealed on the basis that the income was taxable either in 1916 when it was earned, or 1922 when the final decision regarding the land ...
In reaching this decision, the Court looked to the seminal case setting forth the tax code's definition of gross income, Commissioner of Internal Revenue v. Glenshaw Glass Co. , [ 5 ] in which the Supreme Court held that a taxpayer has gross income when he has "an accession to wealth, clearly realized, and over which the taxpayers have complete ...
Commissioner of Internal Revenue, 54 T.C. 742 (1970), [1] aff'd on other grounds, 445 F.2d 985 (10th Cir. 1971), [2] cert. denied, 404 U.S. 940 (1971), [3] is a case in which the United States Tax Court stated the principle that where the court of appeals to which an appeal would be made in a given case has already established a rule of ...