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67 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 86 FR 708 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm…
    IRCFinal Rules (FR)Jan 6, 2021
    …institution's internal control processes, which have not been found to be inadequate by the FDIC. § 324.121 [Amended] 25. Section 324.121 is amended by removing “§ 324.10(c)(1) through (3)” and adding “§ 324.10(d)(1) through (3)” in paragraph (c). § 324.132 [Amended] 6. Section 324.132 is amended by removing “§ 324.10(…
  2. 84 FR 13814 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm…
    IRCProposed Rules (FR)Proposed Apr 8, 2019
    easons set out in the joint preamble, the FDIC proposes to amend 12 CFR part 324 as follows. PART 324—CAPITAL ADEQUACY OF FDIC—SUPERVISED INSTITUTIONS * * * * * 12 CFR Part 324 Authority and Issuance For the reasons set out in the joint preamble, the FDIC proposes to amend 12 CFR part 324 as follows: PART 324—CAPITAL A…
  3. Notice 2026-49 — Guidance on Section 324 of the SECURE 2.0 Act with Respect to Rollovers
    IRCNoticesAug 24, 2026
    Notice 2026-49 I. PURPOSE Section 324 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 4459 (2022), known as the SECURE 2.0 Act of 2022 (SECURE 2.0 Act) provides that the Secretary of the Treasury or the Secretary’s delegate must develop and issue guidance, in the form of sample fo…
  4. 84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements
    IRCFinal Rules (FR)Nov 1, 2019
    42. In § 324.22, revise paragraph (b)(2)(ii) to read as follows: § 324.22 Regulatory capital adjustments and deductions. * * * * * (b) * * * (2) * * * (ii) An FDIC-supervised institution that is not an advanced approaches FDIC-supervised institution must make its AOCI opt-out election in the Call Report: (A) If the FDI…
  5. 83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements
    IRCProposed Rules (FR)Proposed Dec 21, 2018
    as follows. PART 324—CAPITAL ADEQUACY OF FDIC-SUPERVISED INSTITUTIONS 25. The authority citation for part 324 continues to read as follows: Authority: 12 U.S.C. 1815(a), 1815(b), 1816, 1818(a), 1818(b), 1818(c), 1818(t), 1819(Tenth), 1828(c), 1828(d), 1828(i), 1828(n), 1828(o), 1831o, 1835, 3907, 3909, 4808; 5371; 5412…
  6. 81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCProposed Rules (FR)Proposed Jun 1, 2016
    … CFR part 329 (FDIC). Back to Citation 25.   See 12 CFR 3.2 (OCC), 12 CFR 217.2 (Board), and 12 CFR 324.2 (FDIC). Back to Citation 26.   See section II.D and II.C of this Supplementary Information section for discussion of assignment of RSF and ASF factors, respectively. Back to Citation 27.   See 12 CFR 3.2 (OCC), 12 …
  7. 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
    … CFR part 252. Back to Citation 16.   See 12 CFR part 217 (Board); 12 CFR part 3 (OCC); 12 CFR part 324 (FDIC). Back to Citation 17.   See Subpart D of the regulatory capital rule, 12 CFR part 217 (Board); 12 CFR part 3 (OCC); 12 CFR part 324 (FDIC). Back to Citation 18.   See 12 CFR 217.1(c), 12 CFR 217.100(b) (Board)…
  8. 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 — …
  9. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  10. 86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCFinal Rules (FR)Feb 11, 2021
    …ty tier 1 capital, additional tier 1 capital, and tier 2 capital, in each case as defined in 12 CFR 324.20, prior to application of capital adjustments or deductions as set forth in 12 CFR 324.22, excluding any debt or equity instrument that does not meet the criteria for additional tier 1 or tier 2 capital instruments…
  11. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    least 95 percent of the active participants in the terminated plan who remain as employees of the employer after the termination. Sec. 4980(d)(2)(A)↩. 5. See Estate of Young v. Commissioner, 81 T.C. 879↩ (1983) (holding this Court generally lacks jurisdiction over the sec. 6651(a)(2) addition to tax for failure to pay …
  12. T.C. Summary Opinion 2002-52 — Daniel R. & Margaret J. Kallmyer v. Commissioner
    IRCCourt RulingsMay 9, 2002related by meaning
    ven report the distributions. the clear intent of Congress to prevent voluntary withdrawals, we decided that the penalty was inapplicable. Id. at 291. Petitioners’ reliance on Larotonda v. Commissioner , supra , is misplaced. Here, respondent did not levy on the retirement accounts. Petitioners made voluntary withdrawa…
  13. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991
    …xes as follows: Anton Zabolotny Year 1981 1982 1983 1984 1985 1986 First-tier (initial) deficiency $324,095.75 324,095.75 324,095.75 324,095.75 324,095.75 324,095.75 Additions to tax sec. 6651 $81,023.94 81,023.94 81,023.94 81,023.94 64,819.15 For taxable year ended November 26, 1986, respondent determined a second-tie…
  14. 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…
  15. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  16. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    ioner's retirement distribution's being taxed twice. We think petitioners' contention is meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended by Congress. E.g., Maass v. Higgins , 312 U.S. 443, 449 (1941); United States v. Supplee-Biddle Hardware …
  17. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  18. 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…
  19. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  20. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…