IRCCourt RulingsOct 3, 1989
…ricted persons.” Petitioner claimed employee recreational expense deductions under sections 162 and 274(e)(5) (now section 274(e)(4) for amounts paid for the charters during the taxable years 1980 and 1981 in the respective amounts of $8,000 and $41,000. These deductions were disallowed by the Commissioner. The sole is…
IRCCourt RulingsJul 14, 2005
…roving error in
respondent's determination in the notice that petitioner was
subject to the section 274(n)(1) limitation with respect to the per diem amounts that TLC paid to each driver-employee. Thus,
the Court's holding that TLC was subject to that section
274(n)(1) limitation resulted in the Court's sustaining
resp…
IRCCourt RulingsMar 11, 2020
Sec. 1.274-5T(b)(6), (c)(1), Temporary Income Tax Regs., 50 Fed. Reg.
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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…
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
2 (FDIC) (“synthetic exposure”).
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32.
See 12 CFR 3.2 (OCC); 12 CFR 217.2 (Board); 12 CFR 324.2 (FDIC) (“investment in the capital of an unconsolidated financial institution” and “indirect exposure”).
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33.
See 12 CFR 44.4 (OCC); 12 CFR 248.4 (Board); 12 CFR 351.4 (FDIC).
Back to Citat…
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
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taxpayer's own statement any item with respect to an activity
which is of a type generally considered to…
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023
ation
133.
Proposed 26 CFR 54.9816-8(b)(2)(ii)(A)(
5), 29 CFR 2590.716-8(b)(2)(ii)(A)(
5), and 45 CFR 149.510(b)(2)(ii)(A)(
5).
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134. Currently, the administrative fee is paid to the selected certified IDR entity and then remitted to the Departments. 26 CFR 54.9816-8T(d)(2)(i) and (e)(2)(ix), 29 CFR 2…
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,…
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”, …
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
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…
T.D. 9836 — These final regulations provide guidance regarding substantiation and reporting requirements for cash and noncash charitable contributions. The final regulatio… IRCTreasury DecisionsAug 13, 2018related by meaning
…Control numbers.
* * * * *
(b) * * *
______________________________________________________________
CFR part or section where Current OMB
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
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
…lecting real property trade or business under section 163(j)(7)(B) of the Internal Revenue Code.
26 CFR 601.601. Rules and regulations. (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…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
90 FR 23303 — Request for Information Regarding the Prescription Drug Machine-Readable File Requirement in the Transparency in Coverage Final Rule IRCProposed Rules (FR)Proposed Jun 2, 2025
.210(a)(2)(xi).
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20.
26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D).
21. The TiC final rules also clarify that nothing in 26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D) requires th…
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]