For Tax Professionals  

1998 & 1997 IRS Actions on Decisions Library

All Actions on Decisions for 1998 are only available in Adobe Acrobat PDF format. You will need the appropriate PDF Reader to view, print, or download the PDF version. There are different Acrobat Readers for different platforms. If you do not have the appropriate Acrobat Reader plugged into your browser, click on the link at the bottom of the page to obtain a FREE copy from Adobe. See the bottom of the page for links to AODs issued in other years.

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.
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.
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.
09/04/1998
McCormick v. Peterson
Issue: Whether the taxpayer was subject to the frivolous return penalty under section 6702.
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.
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).
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.
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?
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.
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.
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).
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).
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.
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.
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.
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).
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.
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.
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.
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.
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?
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.

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