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Go to 106 T.C. 274 (not yet in the library — opens the official source)
65 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    …ny Client Case at Docket No. John and Kimberly Kohler 1026-01 (NBS Trucking) Joseph and Barbara Hix 1062-01
  2. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989★ strong match
    …nal 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 that the recreational activitie…
  3. 81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCProposed Rules (FR)Proposed Jun 1, 2016
    rs and counterparties other than retail mortgages, described in §§ __.106(a)(5)(ii), __.106(a)(5)(v), __.106(a)(6)(ii), and __.106(a)(7)(ii) (row 25); (xi) The weighted amount and, for each applicable maturity category, the unweighted amount of secured lending transactions, unsecured wholesale lending, and lending to r…
  4. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001
    …acts and circumstances) and sufficient information as to each element of every business use. Sec. 1.274-5T(c)(2)(i) and (ii), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). As pertinent here, section 1.274-5T(c)(3)(ii), Temporary Income Tax Regs., 50 Fed. Reg. 46021 (Nov. 6, 1985), entitled “Sampling”, …
  5. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020★ strong match
    Sec. 1.274-5T(b)(6), (c)(1), Temporary Income Tax Regs., 50 Fed. Reg. - 11 - 46016-46017 (Nov. 6, 1985). Section 1.274-5T(c)(2), Temporary Income Tax Regs., 50 Fed. Reg. 46017-46018 (Nov. 6, 1985), provides in relevant part that "adequate records" generally consist of an account book, a diary, a log, a statement of ex…
  6. 86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCFinal Rules (FR)Feb 11, 2021
    or entity or a consolidated subsidiary of a financial sector entity, described in §§ 249.106(a)(3)(ii), 249.106(a)(4)(ii), and 249.106(a)(7) (row 24); (x) The average weighted amount and, for each applicable maturity category, the average unweighted amount of secured lending transactions and unsecured wholesale lending…
  7. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …. (Vol. 1) 521, 583; S. Repti 951263, at 174-175 (1978), 1978-3 C.B. (Vol. 1) 315, 472-473. Section 274(d) requires the taxpayer to substantiate by adequate records or by sufficient evidence corroborating the - 56 - taxpayer's own statement any item with respect to an activity which is of a type generally considered to…
  8. U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner
    IRCCourt RulingsDec 13, 2018
    …ver, is superseded--that is, estimates are not permitted--for certain expenses specified in section 274; to wit, traveling expenses (including meals and lodging while away from home), entertainment expenses, gifts, and "listed property" (including passenger vehicle) expenses.8 Secs. 274(d), 280F(d)(4)(A)(i); sec. 1.274…
  9. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
  10. T.C. Memo. 2012-37 — Ifeanyi David & Ann Ada Onyekwena v. Commissioner
    IRCCourt RulingsApr 26, 2012
    …f such expenditure, (2) time and place of the travel, and (3) business purpose of the expense. Sec. 274(d); sec. 1.274-5T(a) and (b), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). To satisfy the adequate records requirement of section 274(d), the taxpayer shall maintain an account book, a diary, a log,…
  11. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …
  12. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010
    …t specific substantiation requirements to be allowed a deduction under section 162. See, e.g., sec. 274(d). The heightened substantiation requirements of section 274(d) apply to: (1) Any traveling expense, including meals and lodging away from home; (2) any item with respect to an activity in thes nature of entertainme…
  13. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
  14. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  15. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …ump sum equal to the - 9 - 10 The transition obligation recognized upon initial application of SFAS 106 does not include “(a) any previously unrecognized post-retirement benefit obligation assumed in a business combination accou nted for as a purchase, (b) a plan initiation, and (c) any plan amendment that improved ben…
  16. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    s, earnings, and reasonable charges) pursuant tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not : rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant to Rev. Proc . 2005-25, lsupra. Held, further, P must include in his gross income the excess contributiorls pursuan…
  17. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003related by meaning
    f proof in this case is affected by the fact that we carefully scrutinize transactions between related parties, Maxwell v. Commissioner , 95 T.C. 107, 116 (1990); C.M. Gooch Lumber Sales Co. v. Commissioner , 49 T.C. 649, 656 (1968), remanded pursuant to stipulation of the parties 406 F.2d 290 (6th Cir. 1969), and that…
  18. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    thod of deferred compensation exists involves an evaluation of the entire arrangement, not merely the time of receipt of compensation by the employee. Petitioner argues that the Secretary has overstepped the bounds of his authority and, in effect, has amended section 404 by regulation. Petitioner says that the Secretar…
  19. T.D. 9932 — Section 162(m)(1) of the Internal Revenue Code generally limits to $1,000,000 the allowable deduction for a taxable year for applicable employee remuneration p…
    IRCTreasury DecisionsJan 19, 2021
    …(Also Part I, §163(j).) T.D. 9939, page 376. These final regulations provide guidance under section 274 of the Internal Revenue Code (Code) regarding certain amendments made to section 274 by the Tax Cuts and Jobs Act of 2017 (TCJA). These final regulations address the elimination of the deduction under section 274 for…
  20. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    been finalized. Moreover, even if the proposed regulation were final, it would not, by its terms, apply to the 1986 loans. See sec. 1.72(p)-1, Q&A-19, Proposed Income Tax Regs. 63 Fed. Reg. 42, 47 (Jan. 2, 1998) (regulation applies to "loans made on or after the date that is three months after the date of publication o…