84 FR 24296 — Changes to Applicability Thresholds for Regulatory Capital Requirements for Certain U.S. Subsidiaries of Foreign Banking Organizations and Application of Liqui… IRCProposed Rules (FR)Proposed May 24, 2019
izations.
Estimated average hours per response:
Sections 249.40(a), 249.110(a), 249.206(a), 249.207(a) (3 respondents)
Reporting (ongoing monthly)—.50 Sections 249.40(b), 249.110(b), 249.206(b), 249.207(a) (3 respondents)
Reporting (ongoing)—.50
Sections 249.40(b)(3)(iv), 249.110(b)(3), 249.206(b)(iv),249. 207(b)(3) (3…
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
…e “unweighted” cell, the average amount of the NSFR derivatives liability amount described in § 249.107(d)(2) (row 12);
(xiii) In the “unweighted” cell, the average amount of the total derivatives liability amount described in § 249.107(e)(2) (row 13);
(xiv) The average weighted amount and, for each applicable maturity…
84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCFinal Rules (FR)Nov 1, 2019
…nd loan holding companies, and foreign banking organizations.
Estimated average hours per response:
249.40(a) (3 respondents)
Reporting (ongoing monthly)—.50
249.40(b) (3 respondents)
Reporting (ongoing)—.50
249.40(b)(3)(iv) (3 respondents)
Reporting (quarterly)—.50
249.22(a)(2) & (a)(5) (23 respondents)
Recordkeeping …
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCProposed Rules (FR)Proposed Dec 21, 2018
is section.
23. In § 249.90, paragraph (b)(3) is revised to read as follows:
§ 249.90
Timing, method and retention of disclosures.
* * * * *
(b) * * * (3) A covered depository institution holding company or covered nonbank company that is subject to the minimum liquidity standard and other requirements of this part pur…
79 FR 61440 — Liquidity Coverage Ratio: Liquidity Risk Measurement Standards IRCFinal Rules (FR)Oct 10, 2014
. In § 249.40, revise paragraph (b)(1) to read as follows:
§ 249.40
Liquidity coverage shortfall: Supervisory framework.
* * * * *
(b)
Liquidity plan. (1) For the period during which a Board-regulated institution must calculate a liquidity coverage ratio on the last business day of each applicable calendar month under …
81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCProposed Rules (FR)Proposed Jun 1, 2016
…egulated institution that is not a secured lending transaction or a security.
* * * * *
16. Amend § 249.22, by revising paragraph (b)(1) to read as follows:
§ 249.22
Requirements for eligible high-quality liquid assets.
* * * * *
(b) * * *
(1) The assets are not encumbered.
* * * * *
17. Amend § 249.30, by revising par…
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
IRCCourt RulingsMay 25, 2005related by meaning
s to expedite litigation
and avoid the expense of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burde…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
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…
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…
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
IRCCourt RulingsMar 20, 1997related by meaning
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
IRCCourt RulingsOct 20, 2003related by meaning
result apparently so at
odds with accepted tax policy.” Darby v. Commissioner
, supra
at
68.
We find that petitioner did not have a basis in the 1999 distribution from his section 401(k) plan, and that petitioner
properly included the full distribution in his 1999 gross income.
Accordingly, we hold that petitioner is l…
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
IRCCourt RulingsOct 8, 2003related by meaning
…hat we carefully scrutinize transactions
between related parties, Maxwell v. Commissioner
, 95 T.C. 107, 116 (1990); C.M. Gooch Lumber Sales Co. v. Commissioner
, 49 T.C.
649, 656 (1968), remanded pursuant to stipulation of the parties
406 F.2d 290 (6th Cir. 1969), and that the service agreement
between Clarkston and J…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
ioners filed their memorandum on February 12, 2014, and
(continued...)
- 63 -
As an exception to the general rule of section 1.61-22(b)(1), Income Tax Regs., an arrangement between an owner and a nonowner of a life insurance
contract is a split-dollar life insurance arrangement if it is either a compensatory
arrangemen…
IRCCourt RulingsAug 24, 1995related by meaning
section 1041. See Balding v. Commissioner, 98 T.C. 368 (1992).
In order to implement the views expressed herein,
An appropriate order will be issued. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules o…