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88 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCProposed Rules (FR)Proposed Jun 1, 2016
    …he agencies may not have considered. VII. Solicitation of Comments on Use of Plain Language Section 722 of the Gramm-Leach-Bliley Act, Public Law 106-102, sec. 722, 113 Stat. 1338, 1471 (Nov. 12, 1999), requires the Federal banking agencies to use plain language in all proposed and final rules published after January 1…
  2. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988related by meaning
    e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted. An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
  3. T.C. Summary Opinion 2002-2 — William J. Phillips, Jr. & Matrona A. Phillips v. Commissioner
    IRCCourt RulingsJan 14, 2002
    … trial memorandum, and it is deemed to have been conceded. See Levin v. Commissioner , 87 T.C. 698, 722-723 (1986), affd. 832 F.2d 403 (7th Cir. 1987).
  4. T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated …
    IRCTreasury DecisionsDec 6, 2021
    …cability. (a) In general. (1) The requirements in §§2590.716-4 through 2590.716-7, 2590.717-1, 2590.722, and 2590.725-1 through 2590.725-4 apply to group health plans and health insurance issuers offering group health insurance coverage (including grandfathered health plans as defined in § 2590.715-1251), except as spe…
  5. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute. II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
  6. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026
    …he administrative record in a similar context . See Estate of Insinga v. Commissioner, 149 F.4th at 722– 26. The D.C. Circuit concluded that the administrative record in that case failed to include evidence that “(i) is material to Mr. Insinga’s award determinations, (ii) was part of the [WBO’s] history of decision-mak…
  7. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
  8. 29 C.F.R. § 2530.200b-2(e) — Hour of service.
    ERISARegulationsJan 1, 2017
    … the end of the computation period or more frequently. Thus, this employee could be credited with 1,722 hours of service (or, if the employer rounded up at the end of each week, 39 hours of service per week, resulting in credit for 1,755 hours of service). (e)(2) (2) During a computation period, an employee was paid fo…
  9. PLR 201149005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 9, 2011
    …es of determining the tax bases that the Trusts have in th eir Partnership Interests under sections 722 and 752(a) and also the amount realized by the Trusts in connection with the proposed sale under section 752(d). Accordingly, we conclude that each Trust will recognize gain or loss as a result of the sale of its Par…
  10. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  11. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995related by meaning
    -2503 at 95-2504, 95-1 USTC par. 50,280 (D. Md. 1995); see also Conway v. United States , supra ; cf. Wheeler v. Commissioner , T.C. Memo. 1993-561. 6 We observe that the definition of "qualified total distribution" set forth in section 402(a)(5)(E)(i)(II) incorporates the definition of "lump sum distribution" set fort…
  12. 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…
  13. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    rough prosecution of a legal suit or action based upon tort or tort type rights, or - 14 - through a settlement agreement entered into in lieu of such prosecution.” Sec. 1.104-1(c), Income Tax Regs. Thus, the exclusion must derive from some sort of tort claim against the payor. Rickel v. Commissioner , 900 F.2d 655, 65…
  14. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023
    …5,080 — Contract labor — 11,200 5,800 — Gifts — 7,600 3,600 3,600 Mileage reimbursement — 26,104 18,722 20,627 Office supplies — 43,700 22,890 8,250 Payroll processing fees — 657 1,274 — Product development — 32,400 15,900 — Professional fees — 12,994 9,743 3,040 Travel — 17,125 11,311 23,964 9 For 2015 KJJJ’s deductio…
  15. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    983). They are among the clearest and most central requirements for favorable tax treatment and cannot be disregarded — deliberately or inadvertently. The amounts in question here ($80,490 and $6,715) were not de minimis, and in a quantitative sense they were material. The error occurred in more than one year, and occu…
  16. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …ase “complete power”. Petitioner argues 44 Section 141 of the Revenue Act of 1934, 48 Stat. at 720- 722, related to the filing of a consolidate d return by an affiliated group of corporations. 79 that this crucial sentence was not in the version of the regulation that was in effect for the tax years at issue in L.E. Sh…
  17. T.C. Memo. 2015-119 — Clement C. Benenson v. Commissioner
    IRCCourt RulingsJun 29, 2015
    …tions on their 2008 Form 1040. Clement filed timely a Form 1040 for tax year 2008. He reported $518,722 of gross income on his 2008 Form 1040. He did not attach a Form 5329, _ 9 _
  18. T.C. Memo. 2000-137 — Alton F. Emerson v. Commissioner
    IRCCourt RulingsApr 12, 2000
    …involved. No single factor controls. See Osteen v. Commissioner , supra ; Brannen v. Commissioner , 722 F.2d 695, 704 (11th Cir. 1984), affg. 78 T.C. 471 (1982); sec. 1.183-2(b), Income Tax Regs. 1. Manner of Carrying on Activity The manner in which the taxpayer carries on the activity is one indication of a profit obj…
  19. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
  20. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001
    …6 joint return, petitioners reported, inter alia, wage income attributable to Mr. Whitehead of $109,722 12 and “Other income” of $8,975. 13 - 22 - 12 (...continued) Whitehead (Mr. Whitehead’s 1996 Form W-2). That form showed “BURIEN NISSAN ADMINISTRATION” as employer and Mr. Whitehead as employee. Mr. Whitehead’s 1996 …