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 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”, …
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026★ strong match
he Departments are modifying 26 CFR 54.9816-8(b)(1)(ii)(A)(
2), 29 CFR 2590.716-8(b)(1)(ii)(A)(
2), and 45 CFR 149.510(b)(1)(ii)(A)(
2) in three ways: (1) regarding the information sufficient to identify a plan or issuer, to remove the language “if the plan or issuer is registered under” § 54.9816-9, § 2590.716-9, an…
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…
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
IRCCourt RulingsMar 11, 2020
Sec. 1.274-5T(b)(6), (c)(1), Temporary Income Tax Regs., 50 Fed. Reg.
- 11 -
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”).
Back to Citation
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”).
Back to Citation
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
- 56 -
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).
Back to Citation
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…
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
…rinted page 26617)
Department and the IRS participated in their development.
List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
Proposed Amendments to the Regulations
Accordingly, 26 CFR part 1 is proposed to be amended as follows:
PART 1—INCOME TAXES
Paragraph 1.
The authority cita…
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,…
REG-115699-09 — Proposed regulations under section 401 of the Code contain proposed amendments to the regulations relating to certain cash or deferred arrangements and matchin… IRCProposed Rules (FR)Proposed Jun 1, 2009related by meaning
graph (g)(2) is satisfied if each eligible employee is given a notice (in writing or such other form as prescribed by the Commissioner) that explains— (i) The consequences of the amendment which reduces or suspends future safe harbor contributions;
(ii) The procedures for changing their cash or deferred elections and, …
IRCRegulationsDec 30, 2016related by meaning
(a) (a) In general. [Reserved]
IRCRegulationsMar 14, 2019related 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…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026related by meaning
Applicability Date
Proposed § 48.6435-1 would apply to removals of eligible dyed fuel occurring on or after December 31, 2025. See section 7805(b)(2). Special Analyses
I. Regulatory Planning and Review
These proposed regulations are not subject to review under section 6(b) of Executive Order 12866 pursuant to the Memor…
IRCRegulationsMar 14, 2019related by meaning
[Reserved]
86 FR 55756 — Requirements Related to Surprise Billing; Part II IRCProposed Rules (FR)Proposed Oct 7, 2021related by meaning
…ve been developed in coordination with personnel from the OPM, DOL, and HHS.
List of Subjects in 26 CFR Part 54
Excise taxes
Pensions
Reporting and recordkeeping requirements
Proposed Amendments to the Regulations
Accordingly, 26 CFR part 54 is proposed to be amended as follows:
PART 54—PENSION EXCISE TAXES
Paragraph. …
IRCRegulationsMar 14, 2019related 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…