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61 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 86 FR 708 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm…
    IRCFinal Rules (FR)Jan 6, 2021
    …institution's internal control processes, which have not been found to be inadequate by the FDIC. § 324.121 [Amended] 25. Section 324.121 is amended by removing “§ 324.10(c)(1) through (3)” and adding “§ 324.10(d)(1) through (3)” in paragraph (c). § 324.132 [Amended] 6. Section 324.132 is amended by removing “§ 324.10(…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  3. 84 FR 13814 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm…
    IRCProposed Rules (FR)Proposed Apr 8, 2019
    easons set out in the joint preamble, the FDIC proposes to amend 12 CFR part 324 as follows. PART 324—CAPITAL ADEQUACY OF FDIC—SUPERVISED INSTITUTIONS * * * * * 12 CFR Part 324 Authority and Issuance For the reasons set out in the joint preamble, the FDIC proposes to amend 12 CFR part 324 as follows: PART 324—CAPITAL A…
  4. 84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements
    IRCFinal Rules (FR)Nov 1, 2019
    42. In § 324.22, revise paragraph (b)(2)(ii) to read as follows: § 324.22 Regulatory capital adjustments and deductions. * * * * * (b) * * * (2) * * * (ii) An FDIC-supervised institution that is not an advanced approaches FDIC-supervised institution must make its AOCI opt-out election in the Call Report: (A) If the FDI…
  5. 83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements
    IRCProposed Rules (FR)Proposed Dec 21, 2018
    as follows. PART 324—CAPITAL ADEQUACY OF FDIC-SUPERVISED INSTITUTIONS 25. The authority citation for part 324 continues to read as follows: Authority: 12 U.S.C. 1815(a), 1815(b), 1816, 1818(a), 1818(b), 1818(c), 1818(t), 1819(Tenth), 1828(c), 1828(d), 1828(i), 1828(n), 1828(o), 1831o, 1835, 3907, 3909, 4808; 5371; 5412…
  6. 81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCProposed Rules (FR)Proposed Jun 1, 2016
    … CFR part 329 (FDIC). Back to Citation 25.   See 12 CFR 3.2 (OCC), 12 CFR 217.2 (Board), and 12 CFR 324.2 (FDIC). Back to Citation 26.   See section II.D and II.C of this Supplementary Information section for discussion of assignment of RSF and ASF factors, respectively. Back to Citation 27.   See 12 CFR 3.2 (OCC), 12 …
  7. 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
    … CFR part 252. Back to Citation 16.   See 12 CFR part 217 (Board); 12 CFR part 3 (OCC); 12 CFR part 324 (FDIC). Back to Citation 17.   See Subpart D of the regulatory capital rule, 12 CFR part 217 (Board); 12 CFR part 3 (OCC); 12 CFR part 324 (FDIC). Back to Citation 18.   See 12 CFR 217.1(c), 12 CFR 217.100(b) (Board)…
  8. Notice 2026-49 — Guidance on Section 324 of the SECURE 2.0 Act with Respect to Rollovers
    IRCNoticesAug 24, 2026
    … 2026-49 I. PURPOSE Section 324 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 4459 (2022), known as the SECURE 2.0 Act of 2022 (SECURE 2.0 Act) provides that the Secretary of the Treasury or the Secretary’s delegate must develop and issue guidance, in the form of sample forms (i…
  9. 86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCFinal Rules (FR)Feb 11, 2021
    …ty tier 1 capital, additional tier 1 capital, and tier 2 capital, in each case as defined in 12 CFR 324.20, prior to application of capital adjustments or deductions as set forth in 12 CFR 324.22, excluding any debt or equity instrument that does not meet the criteria for additional tier 1 or tier 2 capital instruments…
  10. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  11. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …il, 3M Company, and 3M IPC for the 2006 year is $165,783 (equal to $4,283,153 minus an offset of $4,117,370 for unreimbursed research - and -develop ment expenses (R & D offset )) . We interpret the term “minimum section 482 adjustment” to be the minimum section 482 adjustment that would be made if petitioner were to p…
  12. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991
    …xes as follows: Anton Zabolotny Year 1981 1982 1983 1984 1985 1986 First-tier (initial) deficiency $324,095.75 324,095.75 324,095.75 324,095.75 324,095.75 324,095.75 Additions to tax sec. 6651 $81,023.94 81,023.94 81,023.94 81,023.94 64,819.15 For taxable year ended November 26, 1986, respondent determined a second-tie…
  13. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  14. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  15. 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…
  16. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  17. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    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’ …
  18. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998related by meaning
    titioner, WE 7, and - 18 - 4 The complaint filed in the Superior Court indicates that the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987. the Guardian Construction Co., Inc., as corporate partners of Estes Co. Petitioner was identified as a partner…
  19. 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 .
  20. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …