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68 documents · 0.43sAllIRCERISAPBGCJoint Board
  1. Treas. Reg. § 1.421-1(h)(4)(i) — Meaning and use of certain terms.
    IRCRegulationsSep 9, 2016
    (h)(4)(i) (i) Additional definitions. (h)(1) (1) Corporation. For purposes of this section and §§ 1.421-2 through 1.424-1, the term corporation has the meaning prescribed by section 7701(a)(3) and § 301.7701-2(b) of this chapter. For example, a corporation for purposes of the preceding sentence includes an S corporatio…
  2. REG-106251-08 — Proposed regulations under section 423 of the Code provide the requirements that must be satisfied in order for a plan to meet the definition of an employee st…
    IRCProposed Rules (FR)Proposed Sep 29, 2008
    …ss-references. For rules relating to the requisite employment relationship, see paragraph (h) of §1.421-1. For rules relating to the effect of a disqualifying disposition, see section 421(b) and paragraph (b) of §1.421-2. For the definition of the term disposition, see section 424(c) and paragraph (c) of §1.424-1. For …
  3. Treas. Reg. § 1.421-2(a)(2) — General rules.
    IRCRegulationsJan 19, 2017
    …ance of the option more than three months after leaving such employment, the application of section 421 to the stock obtained upon the earlier exercise of the option is not affected by the fact that the income taxes of the employer and the individual with respect to the stock obtained upon the later exercise of the opt…
  4. Treas. Reg. § 1.424-1(c) — Definitions and special rules applicable to statutory options.
    IRCRegulationsJan 19, 2017
    (c) (c) Disposition of stock. (c)(1) (1) For purposes of sections 421 through 424, the term “disposition of stock” includes a sale, exchange, gift, or any transfer of legal title, but does not include— (c)(1)(i) (i) A transfer from a decedent to his estate or a transfer by bequest or inheritance; or (c)(1)(ii) (ii) An …
  5. Treas. Reg. § 1.423-2(g)(2) — Employee stock purchase plan defined.
    IRCRegulationsJan 19, 2017
    …pricing requirements of this paragraph (g). For general rules relating to the option price, see § 1.421-1(e). For rules relating to the determination of when an option is granted, see §§ 1.421-1(c) and 1.423-2(h)(2). Any option that does not meet the minimum pricing requirements of this paragraph (g) will not be treate…
  6. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996★ strong match
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  7. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  8. Treas. Reg. § 1.423-1(b) — Applicability of section 421(a).
    IRCRegulationsSep 9, 2016
    (b) (b) Cross-references. For rules relating to the requisite employment relationship, see § 1.421-1(h). For rules relating to the effect of a disqualifying disposition, see section 421(b) and § 1.421-2(b). For the definition of the term “disposition,” see section 424(c) and § 1.424-1(c). For the definition of the term…
  9. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  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. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    …r affected homeworker Minor Substantial Repeated, intentional or knowing Recordkeeping $21-210 $210-421 $421-1,052 Monetary violations 21-210 210-421 Employment of homeworkers without a certificate 210-421 421-1,052 Other violations of statutes, regulations or employer assurances 21-210 210-421 421-1,052 PART 570—CHILD…
  12. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  13. Treas. Reg. § 1.422-1(a) — Incentive stock options; general rules.
    IRCRegulationsSep 9, 2016
    (a) (a) Applicability of section 421(a). (1)(i) Section 1.421-2(a) applies to the transfer of a share of stock to an individual pursuant to the individual's exercise of an incentive stock option if the following conditions are satisfied— (a)(A) (A) The individual makes no disposition of such share before the later of t…
  14. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  15. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  16. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987related by meaning
    iaries alike, providing assured protection to the former and clear notice of responsibility to the latter. [716 F.2d at 1464-1465. Citations omitted.] After a review of the statutory framework and legislative history of section 4975 and the case law interpreting ERISA section 406, we conclude that the prohibited transa…
  17. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  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. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979related by meaning
    n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …
  20. 77 T.C. 1096 — Cobb v. Commissioner
    IRCCourt RulingsNov 12, 1981related by meaning
    e deductible, there must be a written instrument governing such account which was extant by the time prescribed for the making of such a contribution. During 1975, Mr. Cobb had only a Keogh account. It was not until December 15, 1976, when he executed the account registration statement with Connecticut General, that he…