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78 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans
    IRCFinal Rules (FR)Dec 26, 2013
    Appraisal Safe Harbor Review To qualify for the safe harbor provided in § 226.43(c)(2), a creditor must confirm that the written appraisal: * * * * * 7. Indicates that a physical property visit of the interior of the property was performed, as applicable. * * * * * 9. In Supplement I to part 226, under Section 226.43—…
  2. 78 FR 48548 — Appraisals for Higher-Priced Mortgage Loans-Supplemental Proposal
    IRCProposed Rules (FR)Proposed Aug 8, 2013
    § 226.2—Definitions and rules of construction. (a) Definitions. For purposes of this part, the following definitions apply: * * * * * (6) Business day means a day on which the creditor's offices are open to the public for carrying on substantially all of its business functions. However, for purposes of rescission under…
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    tion 39.45-1 of Regulations 118 to replace section 29.45-1 of Regulations 111. Regulations 118 was a comprehensive set of income- tax regulations that was promulgated, and published in the Federal Register, in 1953. 18 Fed. Reg. 5771 (Sept. 26, 1953); see sec. 39.1-1(a) of Regulations 118, 18 Fed. Reg. 5782. Regulation…
  4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  5. 84 FR 53579 — Real Estate Appraisals
    IRCFinal Rules (FR)Oct 8, 2019
    Board: 12 CFR 226.42; CFPB: 12 CFR 1026.42 (implementing valuation independence amendments to the Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., by Dodd-Frank Act section 1472, 15 U.S.C. 1639e). Back to Citation 64.  Board: 12 CFR 226.42(c)(1); CFPB: 12 CFR 1026.42(c)(1). Back to Citation 65.   See Board: 12 CFR …
  6. Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of …
    IRCRevenue ProceduresModified Dec 29, 2025
    …ed guidance 225 .05 Issues in prior return 225 .06 Generally not to business associations or groups 226 .07 Generally not to foreign governments 226 .08 Generally not on federal tax consequences of proposed legislation 226 SECTION 25. UNDER WHAT CIRCUMSTANCES DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HAVE DISCRETION T…
  7. 87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Jul 27, 2022
    0. Back to Citation 79.  Assuming that the average cost of an exemption audit would be $25,000, 118 QPAMs * $25,000 = $2,950,000. Back to Citation 80.  The burden is estimated as follows: (118 * 5 hours) + (118* 13 hours) + (118 * 6 hours) = 2,832 hours. A labor rate of $140.96 is used for legal counsel, a labor rate o…
  8. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    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…
  9. 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…
  10. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ferences are to the Tax Court Rules of Practice and Procedure. In the case of a corporation, the term “exemption amount” means $40,000. Sec. 55(d)(2). See Illinois Cereal Mills, Inc. v. United States, 74 AFTR 2d 94-6105, 94-2 USTC par. 50,458 (C.D. Ill. 1994). In the instant case, appeal lies with the Court of Appeals …
  11. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    …y not in certain areas because of factual nature of the problem 225 .02 No “comfort” letter rulings 226 .03 Not on alternative plans or hypothetical situations 226 .04 Ordinarily not on part of an integrated transaction 226 .05 Not on partial terminations of employee plans 226 .06 Law requires a letter ruling 226 .07 I…
  12. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  13. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
  14. 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…
  15. Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2023
    …ed exhaustion of administrative remedies 225 .06 Service must have reasonable time to act on appeal 226 .07 Service must have reasonable time to act on request for § 7805(b) relief 226 SECTION 23. WHAT EFFECT WILL A DETERMINATION LETTER HAVE? 226 .01 May be relied on subject to limitations 226 .02 Scope of reliance on …
  16. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  17. T.C. Memo. 1996-354 — Brent Allan Pulliam v. Commissioner
    IRCCourt RulingsAug 1, 1996related by meaning
    1 Unless otherwise indicated, 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. T.C. Memo. 1996-354 UNITED STATES TAX COURT BRENT ALLAN PULLIAM, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket…
  18. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  19. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
  20. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…