REG-106796-12 — These proposed regulations provide guidance on the application of section 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for serv… IRCProposed Rules (FR)Proposed May 28, 2013
…solidated group ending December 31, 2016, are not subject to the deduction limitation under section 162(m)(6). (g) Coordination—(1) Coordination with section 162(m)(1). If section 162(m)(1) and section 162(m)(6) would both otherwise apply with respect to the remuneration of an applicable individual, the deduction limit…
T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov… IRCTreasury DecisionsOct 6, 2014
…, whenever those amounts become otherwise deductible
(g) Coordination—(1) Coordination with section 162(m)(1). If section 162(m)(1) and section 162(m)(6) both otherwise would apply with respect to the remuneration of an applicable individual, the deduction limitation under section 162(m)(6) applies without regard to se…
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…
Notice 2011-2 — This notice provides guidance on the application of section 162(m)(6) of the Code. Section 162(m)(6) limits the allowable deduction for remuneration for servic… IRCNoticesJan 10, 2011
Notice 2011-2
Guidance on the Application of Section 162(m)(6)
I. PURPOSE
This notice provides guidance on the application of section 162(m)(6) of the Internal Revenue Code (Code). Section 162(m)(6) limits the allowable deduction for remuneration for services provided by individuals to certain health insurance provider…
IRCProposed Rules (FR)Proposed Mar 12, 2026
…or part 1 continues to read in part as follows:
Authority:
26 U.S.C. 7805 * * *
* * * * *
Section 1.148-0 through 1.148-11 also issued under 26 U.S.C. 148(i).
* * * * *
Par. 2.
Section 1.148-0 is amended, in paragraph (c), in the table of contents for § 1.148-11, by revising the section heading for § 1.148-11 and addin…
IRCCourt RulingsFeb 9, 2023related by meaning
ory change was
discussed in the “Introduction” portion of the preamble to Treasury
Decision 8470. 58 Fed. Reg. 5264. Treasury Decision 8470 was issued the same day as the notice of proposed rulemaking , January 21, 1993,
setting forth the proposed regulations on foreign legal restrictions. T.D.
8470, 58 Fed. Reg. 5310;…
IRCCourt RulingsMay 20, 1976★ strong match
…nondeferred compensation must be subject to the reasonable allowance standards set forth in section 162(a)(1). Sec. 1.404(a)-1(b), Income Tax Regs. Petitioners contend that if Congress intended section 404(a) to be subject to reasonable compensation standards, it would have specifically mentioned section 162(a)(1). The…
Notice 2008-94 — This notice provides guidance on certain executive compensation provisions of the Emergency Economic Stabilization Act of 2008 (EESA). Section 302 of EESA adde… IRCNoticesNov 3, 2008
Notice 2008-94
Guidance for Sections 162(m)(5) and 280G(e) of the Internal Revenue Code
I. PURPOSE
This notice provides guidance on certain executive compensation provisions of the Emergency Economic Stabilization Act of 2008, Div. A of Pub. Law No. 110-343 (EESA), which was enacted on October 3, 2008. Section 302 of E…
IRCCourt RulingsJan 14, 2013related by meaning
…packages paid to the corporation's
owner-employees were reasonable and deductible under I.R.C. sec.
162, for the 2003, 2004, and 2005 tax years to the extent determined
herein. The compensation paid to the owner-employees' daughter,
Grace-Ann Strick, was unreasonable.
1Cases of the following petitioners are consolidate…
T.D. 9716 — Section 162(m) generally limits the otherwise allowable deduction for compensation paid with respect to a covered employee of a publicly held corporation to no… IRCTreasury DecisionsApr 13, 2015
…calendar year following the calendar year in which the corporation becomes publicly held. Section 1.162–27(f)(3) provides that the relief provided under § 1.162–27(f)(1) applies to any compensation received pursuant to the exercise of a stock option or stock appreciation right, or the substantial vesting of restricted …
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 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…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
e, providers and facilities, and providers of air ambulance services.
B. Part 148—Requirements for the Individual Health Insurance Market
1. Authority HHS proposes to make technical corrections to the authority listed for 45 CFR part 148. More specifically, HHS proposes to update the list to reference the Federal insur…
IRCCourt RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
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…
IRCProposed Rules (FR)Proposed Feb 18, 2025★ strong match
ing a covered employee for a preceding taxable year (as provided in section 162(m)(3)(D)).
II. Determination of the Five Highest Compensated Employees These proposed regulations would use “compensation” as defined in paragraph (c)(3) of the current regulations (that is, compensation that would (but for section 162(m)) …
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
- 23 -
(3) If at any time the correction of the
error is authorized as to one such t…
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…
IRCCourt RulingsJul 18, 1968related by meaning
… T.C. 462, provided in part (sec. 542(c) (9)):
provided that the deductions allowable under section 162 (relating to trade or business expenses), other than compensation for personal services rendered by shareholders (including members of the shareholder’s family as described in section 544(a)(2)), constitute 15 percen…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…