For Tax Professionals  

1999 IRS Actions on Decisions Library

All Actions on Decisions for 1999 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.

Duke Energy Natural Gas Corporation v. Commissioner
Issue: Whether, for depreciation purposes, a taxpayer engaged in the business of pipeline transmission of natural gas, who is not a producer of natural gas, must include gathering pipelines in asset class 46.0 Pipeline Transportation (15-year recovery period) or in class 13.2 Exploration for and Production of Petroleum and Natural Gas Deposits (7-year recovery period)?
Conway v. Commissioner
Issue: Whether a taxpayer's partial surrender of an annuity contract and direct transfer of the resulting proceeds for the purchase of a new annuity qualifies as a nontaxable exchange under I.R.C. § 1035?
William & Helen Woodral v. Commissioner
Issue: To the extent that petitioners' claim for abatement of interest on employment taxes arises under I.R.C. § 6404(a), whether the Tax Court lacks jurisdiction to review the Internal Revenue Service's denial of that claim, i.e., whether the Court's jurisdiction is limited to reviewing the denial of claims brought under section 6404(e).
Mutual Assurance, Inc. v. United States
Issue: Whether a timely filed claim for refund that was allowed in full may be amended after the expiration of the statute of limitations for filing a claim for refund.
Dubin v. Commissioner
Issue: Whether partnership items reported on a joint return convert to nonpartnership items with respect to both spouses when a TEFRA conversion event, pursuant to I.R.C. § 6231, occurs as to only one spouse.
RJR Nabisco, Inc., et al., v. Commissioner
Issue: Whether graphic design and advertising campaign costs incurred by petitioner are currently deductible business expenses under I.R.C. § 162 or are properly treated as capital expenditures under I.R.C. § 263.
James J. & Sandra A. Gales v. Commissioner
Issue: Whether advance commissions received on insurance written by taxpayer husband were income at the time paid or were loans such that income was reportable only as the commissions were subsequently earned.
Boyd Gaming Corporation v. Commissioner
Issue: Whether a meal furnished by the taxpayer/employer on its business premises to an employee is furnished for "the convenience of the employer" within the meaning of that phrase in section 119 of the Internal Revenue Code.
Hospital Corp. of America & Subsidiaries v. Commissioner
Issues: 1. Whether the tests developed under the investment tax credit (ITC) prior to the 1981 adoption of the cost recovery system are applicable in determining a structural component for the purposes of Accelerated Cost Recovery System (ACRS) and Modified Accelerated Cost Recovery System (MACRS). 2. Whether certain items treated as tangible personal property and depreciated over a 5-year recovery period were in fact structural components of the buildings to which they relate which must be depreciated over the same recovery period as the buildings, pursuant to I.R.C. § 168.
Vulcan Materials Company and Subsidiaries v. Commissioner
Issue: Whether the term "accumulated profits" as used in the denominator of the section 902 deemed paid credit fraction before the Tax Reform Act of 1986 means all of a foreign corporation's accumulated profits for the taxable year. This revised action on decision clarifies the Service's position on this issue in cases appealable to the 11th Circuit.
Estate of Mellinger v. Commissioner
Issue: Whether, for estate tax valuation purposes, a minority interest in a closely-held corporation held in a Qualified Terminable Interest Property (QTIP) trust, which is includible in the gross estate under I.R.C. § 2044, is aggregated with a minority interest in the same corporation that is includible in a decedent's gross estate under other provisions of the Code.
St. Jude Medical, Inc. v. Commissioner
Issue: Whether section 1.861-8(e)(3) of the Income Tax Regulations is invalid as applied to DISC combined taxable income (CTI) calculations.
Internal Revenue Service v. Waldschmidt (In re Bradley)
Issue: Whether gain on the sale of the debtor's residence is excluded from gross income of the bankruptcy estate to the extent provided by I.R.C. §121 and in accord with section 1398.
Oshkosh Truck Corporation v. United States
Issue: Whether the 12-percent excise tax imposed under I.R.C. § 4052 on the first retail sale of specially designed trucks to the United States Army is computed by adding to the vehicle sales price a "presumed markup percentage" as described in subsections (b)(3) and (4) of section 4052 and Treas. Reg. § 145.4052-1(d)(7).
Murillo v. Commissioner
Issue: Whether the forfeiture of an Individual Retirement Account ("IRA") to the United States pursuant to a civil proceeding causes the IRA owner to be liable for the 10 percent early distribution tax under I.R.C. § 72(t).
Larotonda v. Commissioner
Issue: Whether petitioner's constructive receipt of a Keogh account distribution by virtue of the government's levy on the account causes the Keogh owner to also be liable for the 10 percent early distribution tax under I.R.C. § 72(m)(5).
Eisenberg v. Commissioner
Issue: Whether a discount for potential capital gains tax liabilities may be applied in valuing closely-held stock.


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