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Go to 86 T.C. 1253 (not yet in the library — opens the official source)
44 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov…
    IRCTreasury DecisionsAug 15, 2016related by meaning
    s in order to comply with their FATCA obligations, unless the FFIs qualify for an exemption under the FATCA regulations. Notice 2016–48 Notice 2016–48 This Notice explains how the IRS will implement the changes to the Individual Taxpayer Identification Number (ITIN) program resulting from the enactment of the Protectin…
  2. 72 T.C. 1088; 1 Employee Benefits Cas. (BNA) 1830 — Caterpillar Tractor Co. v. Commissioner
    IRCCourt RulingsSep 13, 1979related by meaning
    OPINION Tannenwald, Judge: Petitioner seeks a declaratory judgment pursuant to section 7476 that its noncontributory pension plan, as amended December 17, 1976, qualifies under section 401(a). The case was submitted under Rule 122, Tax Court Rules of Practice and Procedure, on the basis of the pleadings and the facts s…
  3. Notice 2016-3 — This notice provides that the Treasury and the IRS will issue guidance with respect to (1) Cycle A elections made by controlled groups and affiliated service g…
    IRCNoticesJan 19, 2016related by meaning
    lude identity protection services provided to employees or other individuals before a data breach occurs. EMPLOYEE PLANS Notice 2016–03 Notice 2016–03 This notice provides that the Treasury and the IRS will issue guidance with respect to (1) Cycle A elections made by controlled groups and affiliated service groups; (2)…
  4. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.