IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
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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. …
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
…mount of retail deposits other than stable retail deposits or brokered deposits, described in § 249.104(c)(1) (row 6); (vii) The average weighted amount and, for each applicable maturity category, the average unweighted amount of sweep deposits, brokered reciprocal deposits, and brokered deposits provided by a retail c…
IRCCourt RulingsDec 29, 2005related by meaning
lusion, we need not decide
respondent's contention regarding the fact that petitioner did
not receive a determination from the United States competent authority as to whether the French retirement plan generally
corresponds to a United States retirement plan or that certain
documents, including Exhibits 9-P and 12-P, a…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
tment. Sec. 452 (b) (2); sec. 40.452-1, Regs. 130. Here, the petitioner has not maintained an inconsistent position within the meaning of section 452. It does not insist that the deduction for officers’ compensation in the fiscal year 1941 was improperly claimed. It does not maintain that any portion of such compensati…
IRCCourt RulingsFeb 9, 2023
of the $5,104,756
trademark royalty payment can be viewed as a $0 adjustment because
respondent agrees with the tax reporting of this amount by the 3M consolidated group. Equivalently, one can think of respondent’s position
on the tax treatment of the $ 5,104,756 trademark royalty payment as
comprising two separate ste…
IRCRegulationsSep 9, 2016
…e applicable interest rate that applies to any distribution that is subject to the rules of section 417(e)(3) is assumed to be 52 1/2 percent, and the applicable mortality table under section 417(e)(3) and § 1.417(e)-1(d)(2) is assumed to be the table that applies as of January 1, 2003. In addition, solely for purposes…
81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCProposed Rules (FR)Proposed Jun 1, 2016
…amount of retail deposits other than stable retail deposits or brokered deposits, described in § __.104(c)(1) (row 6); (vii) The weighted amount and, for each applicable maturity category, the unweighted amount of brokered deposits provided by a retail customer or counterparty described in §§ __.104(c)(2), __.104(c)(3)…
IRCCourt RulingsMar 31, 1997related by meaning
individual employer
contributors to determine their deduction limits in the tenebrous
context of overlapping tax and plan years. Consequently, section 404(a)(6), by its reference to section 404(a)(1) through (3), has
an impact on section 413(b)(7).
Petitioner maintains that, if an individual employer's tax
treatment of…
IRCCourt RulingsOct 16, 2001related by meaning
…71-131; White v. Commissioner
,
T.C. Memo. 1979-6.
Petitioners claim that the instruction booklet (“1040 Forms
and Instructions”) they used in the preparation of their return
is misleading. Putting aside the point that the statute is clear
and is controlling, the instructions to which petitioners refer
clearly provides…
ERISARegulationsApr 25, 2023
… with respect to the following:
(g)(1) (1) A totally unfunded welfare plan described in 29 CFR 2520.104-44(b)(1)(i);
(g)(2) (2) A welfare plan which meets the requirements of 29 CFR 2520.104-20(b);
(g)(3) (3) An apprenticeship or other training plan which meets the requirements of 29 CFR 2520.104-22;
(g)(4) (4) A pensi…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
IRCCourt RulingsFeb 15, 1979related by meaning
loyees, which have less generous plans or no plans at all, this would generally constitute an impermissable discrimination. * * * [Emphasis supplied.] We believe that a fair reading of section 414(b) would have alerted petitioner to the fact that such section requires, inter alia, that an affiliated group- comprised of…
IRCRegulationsMay 18, 2016
…3, 1984, and, as of that date had attained age 34, the plan will satisfy the requriement of section 417(a)(3)(B) if it provided the explanation not later than December 31, 1985. Q-36: How do plans satisfy the requirements of providing participants explanations of QPSAs and QJSAs? A-36. For rules regarding the explanati…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
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for 1982 and that the related notice …
T.D. 9076 — Final regulations under section 417(a)(7) of the Code relate to a special rule which permits the required written explanations of certain benefits to be provid… IRCTreasury DecisionsSep 22, 2003
…s added to the Code by section 1451(a) of the Small Business Job Protection Act of 1996, Public Law 104-188 (110 Stat. 1755) (SBJPA), creates an exception to the rules of section 417(a)(3)(A), effective for plan years beginning after December 31, 1996. Section 417(a)(7)(A) provides that, notwithstanding any other provi…
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…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…n 100 participants to be small entities.[99] The basis of this definition is found in ERISA section 104(a)(2), which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under ERISA section 104(a)(3), the Secretary may also provide for exemptions or sim…
IRCProposed Rules (FR)Proposed May 13, 2026
…r than 100 participants to be small entities.[185] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)(3) of ERISA, the Secretary may also provide for exemp…
IRCCourt RulingsMar 11, 2020related by meaning
little more than guesswork and failed to satisfy the strict substantiation
requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan
v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section
274(d). Cons…