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69 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 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
    , as defined in 12 CFR 252.61, or that is pari passu or subordinated to any eligible debt security issued by the global systemically important BHC; or (2) Issued by a Covered IHC, as defined in 12 CFR 252.161, and that is an eligible Covered IHC debt security, as defined in 12 CFR 252.161, or that is pari passu or subo…
  2. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989★ strong match
    the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
  3. 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
    2017); 12 CFR part 252, subparts G and P. The TLAC rule's TLAC and long-term debt requirements took effect on January 1, 2019. Back to Citation 12.   See 12 CFR 252.62 and 252.63; 12 CFR 252.162 and 252.165. The requirements applicable under the TLAC rule to covered BHCs and covered IHCs are similar but not identical.…
  4. 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
    …nt for global systemically important banks issued by the BCBS, as updated from time to time. 12 CFR 252.2. Back to Citation 70.   See 12 CFR 252.82(b) (definition of “covered entity” with regard to restrictions on qualified financial contracts); 12 CFR 252.160 (definition of “covered IHC” with regard to total loss-abso…
  5. IRCCourt RulingsAug 3, 1979related by meaning
    as IRAs) in their respective names at the State Savings Co. in Columbus, Ohio, in the amounts set forth in table I. TABLE I Petitioner-employee Amount John L. Guest .$1,400 James Ventresca . 1,000 Jerome Kobos . 1,000 Edward Andrew Prebihalo . 1,000 Lorraine A. Heitchue . 1,400 Michael P. Grant . 1,000 Paul A. Vlahutin…
  6. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  7. 83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements
    IRCProposed Rules (FR)Proposed Dec 21, 2018
    aning as in 12 CFR 252.2. * * * * * Call Report means the Consolidated Reports of Condition and Income. Category II FDIC-supervised institution means: (1) An FDIC-supervised institution that is a consolidated subsidiary of a company that is identified as a Category II banking organization pursuant to 12 CFR 252.5 or 12…
  8. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  9. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
  10. 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…
  11. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational 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 tha…
  12. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
  13. 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…
  14. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…
  15. 111 T.C. No. 15 — John F. Romann v. Commissioner
    IRCCourt RulingsNov 4, 1998related by meaning
    eafter received his SPB monthly. Petitioner retains a valid chief engineer’s license issued by the U.S. Coast Guard for standby use if needed by MEBA. On August 22, 1991, petitioner elected to forgo continued health care coverage through MEBA Medical. Petitioner checked option one and signed the election form discussed…
  16. 110 T.C. No. 1 — Nurit Haramgaal v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    ime of his distribution, we hold that he is not liable for the sec. 72(t) additional tax. In the notice of deficiency, there was no determination that petitioners Robert C. and Mary D. Borman were liable for the sec. 72(t) additional tax, but on brief, respondent made such an assertion. See sec. 6214(c). 10-percent add…
  17. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  18. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    acted section 7476 to establish a declaratory judgment procedure under which an - 6 - employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept. 93-807, supra at 107, 1974-3 C.B. at 342. Section 7476 provides: SEC. 7476. DECLARATORY JUDGMENTS RELATING TO…
  19. 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…
  20. 68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner
    IRCCourt RulingsSep 12, 1977related by meaning
    r, 68 T.C. 826 (1977). In view of concessions made by the parties and our conclusions on the disputed issues, Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated. Variances between this schedule and Form 4848 reflect persons …