84 FR 24296 — Changes to Applicability Thresholds for Regulatory Capital Requirements for Certain U.S. Subsidiaries of Foreign Banking Organizations and Application of Liqui… IRCProposed Rules (FR)Proposed May 24, 2019
…tate nonmember banks and state savings associations.
Estimated average hours per response:
Sections 329.40(a), 329.110(a) (2 respondents)
Reporting (ongoing monthly)—.50
Sections 329.40(b), 329.110(b) (2 respondents)
Reporting (ongoing)—.50
Sections 329.40(b)(3)(iv), 329.110(b)(3) (2 respondents)
Reporting (quarterly)—…
84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCFinal Rules (FR)Nov 1, 2019
* * *
50. In § 329.10, revise paragraph (a) to read as follows:
§ 329.10
Liquidity coverage ratio.
(a)
Minimum liquidity coverage ratio requirement. Subject to the transition provisions in subpart F of this part, an FDIC-supervised institution must calculate and maintain a liquidity coverage ratio that is equal to or…
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
encumbered.
* * * * *
30. Amend § 329.30, by revising paragraph (b)(3) to read as follows:
§ 329.30
Total net cash outflow amount.
* * * * *
(b) * * * (3) Other than the transactions identified in § 329.32(h)(2), (h)(5), or (j) or § 329.33(d) or (f), the maturity of which is determined under § 329.31(a), transactions t…
83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCProposed Rules (FR)Proposed Dec 21, 2018
3. In § 329.30, paragraph (a) is revised to read as follows:
§ 329.30
Total net cash outflow amount.
(a)
Calculation of total net cash outflow amount. As of the calculation date, an FDIC-supervised institution's total net cash outflow amount equals the FDIC-supervised institution's outflow adjustment percentage as dete…
81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCProposed Rules (FR)Proposed Jun 1, 2016
…pervised institution that is not a secured lending transaction or a security.
* * * * *
26. Amend § 329.22, by revising paragraph (b)(1) to read as follows:
§ 329.22
Requirements for eligible high-quality liquid assets.
* * * * *
(b) * * *
(1) The assets are not encumbered.
* * * * *
27. Amend § 329.30, by revising par…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsFeb 9, 2023related by meaning
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
T.C. Memo. 2016-10 — Family Chiropractic Sports Injury & Rehab Clinic, Inc. v. Commissioner IRCCourt RulingsJan 19, 2016related by meaning
iction over the petition. See, e.g., Efco Tool Co. v. Commissioner, 81 T.C.
976 (1983).
In this declaratory judgment proceeding we review respondent's determination that the plan was not qualified. The standard for our review was
enunciated in Buzzetta Constr. Corp. v. Commissioner, 92 T.C. 641, 648 (1989),
as follows:…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCCourt RulingsFeb 18, 1998related by meaning
lure to report any portion of
the distributions. Thus, we find petitioner liable for the
negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock.
In keeping with the above holdings,
Decision will be entered
under Rule 155
.
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…