§230

45 cases·2 overruled·43 cited

Statute text not available for this section.

45 Citing Cases

§ 230.501(a) (2006). Variable life insurance is a form of cash value insurance. Under traditional cash value insurance, the policyholder typically pays a level premium during life and the beneficiary receives a fixed death benefit. Under a variable policy, both the premiums and the death benefit may fluctuate. The assets held for the benefit of the

These exceptions allow the issuance of unregistered securities as long as both offerors and purchasers reside in the same state. Since SBCC and Investors Prime were both California entities, this meant that it could sell interests only to California residents. SBC Portfolio relied on section 4(2) of the Securities Act of 1933, ch.

230.501(a) (2006). Variable life insurance is a form ofcash value insurance. Under traditional cash value insurance, the insured typicallypays a level premium during life and the beneficiary receives a fixed death benefit. Under a variable policy, both the premiums and the death benefit may fluctuate. The assets held for the benefit of the pol

Ramon Reynoso, Petitioner T.C. Memo. 2013-25 · 2013

1402(b)(1) provides that a taxpayer's self-employmentincome shall not include "that part ofthe net earnings from self-employmentwhich is in excess of(i) an amount equal to the contribution and benefit base (as determined under section 230 ofthe Social Security Act) which is effective for the calendar year in which such taxable year begins, minus (ii) the amount ofwages paid to such individual during suchtaxable years".

Yvonne R. & Robert E. Kovacevich, Petitioner T.C. Memo. 2009-160 · 2009

hes are partly correct about the "contribution basis;" section 3121(a) exempts from wages subject to part of the FICA tax : that part of the remuneration which, after remuneration * * * equal to the contribution and benefit base (as determined under section 230 of the Social Security Act) with respect to employment has been paid to an individual by an employer during the calendar year with respect to which such contribution and benefit base is effective, is paid to such individual by such employ

230.144 (1972), imposing a 2- year holding period on the resale of restricted stock. In 1990, the SEC adopted rule 144A, 17 C.F.R. sec. 230.144A (1990), allowing institutional buyers to buy and sell restricted stock. In 1997, the SEC amended rule 144, 17 C.F..R. sec. 230.144 (1997), reducing the required holding period to 1 year. For the first

section 230.144 (1999) (SEC Rule 144), the estate would not be allowed to sell to the public more than 277,860 of its 3,601,267 restricted Reliance shares in any 3-month period.4 Thus, selling the estate’s 3,601,267 Reliance shares in the public market under the SEC Rule 144 sales restriction would take a minimum of approximately 3 years and 3 mont

John S. & Christobel D. Rendall, Petitioner T.C. Memo. 2006-174 · 2006

230.144 (2006)) was promulgated by the SEC. - 11 - Failure To Complete the Initial Stage Plant Solv-Ex had continued to make modifications to its initial stage plant in Alberta during April 1997, but, because it could not obtain anticipated financing, Solv-Ex began to mothball the plant in late May 1997. Toward the end of June 1997, Mr. Renda

Linda Olson, Petitioner T.C. Memo. 2004-197 · 2004

230.144 (2004), for public transfers, we do not find (nor has petitioner pointed us to) any evidence in the record upon which to determine such a discount.

230.144(d)(1) (1996). The required holding period was shortened to 1 year in 1997. See 62 Fed. Reg. 9242 (Feb. 28, 1997). - 48 - relies primarily on data from the restricted stock approach to support a marketability discount of 35 percent, although he also contends that data from the IPO approach strongly support that level of discount. Dr. B

Clarissa W. Lappo, Petitioner T.C. Memo. 2003-258 · 2003

230.144(d)(1) (1996). In 1997 the required holding period was shortened to 1 year. See 62 Fed. Reg. 9242 (Feb. 28, 1997). - 23 - stock. He determined that these 39 transactions occurred at prices reflecting discounts of 5.2 percent to 57.6 percent from the public-market price, with the median discount being 29.3 percent. Thirteen of the 39 co

230.144(d)(1) (1996). In 1997, the required holding period was shortened to 1 year. See 62 Fed. Reg. 9242 (Feb. 28, 1997). 11 Initial public offering (IPO) studies compare the private-market price of shares sold before a company goes public with the public-market price obtained in the IPO of the shares or shortly thereafter. See McCord v. Comm

Mortimer Z. Landsberg, Proprietor, Petitioner T.C. Memo. 2001-105 · 2001

er argues that in the case of a taxpayer subject to - 5 - community property laws, the intended and exclusive purpose of section 1402(a)(5)(A) is to prevent the application of the self- employment tax to that part of the taxpayer’s net earnings from self-employment that would otherwise exceed the contribution and benefits base as determined under section 230 of the Social Security Act.

J. Randall & Jane B. Groves, Petitioner T.C. Memo. 1999-415 · 1999

230.144 (1984), prohibited petitioner from selling the OPCS stock that he bought from Mrs. Karp for 2 years. - 8 - He was required to report on SEC Form 144 the number of shares he proposed to sell and his acquisition date. For each proposed sale of OPCS stock in 1988 and 1989 by petitioners, petitioners submitted to their stock broker and to

Jean D. Barnes, Donor, Petitioner T.C. Memo. 1998-413 · 1998

230.144 (1984), restricted securities eventually become freely tradeable through either registration or the passage of time. -28- 3. Conclusion--Discounts Based on the arguments of the parties and the record, we conclude that discounts for lack of marketability of 40 percent for the Home stock and 45 percent for the Rock Hill stock are approp

230.144 (1992) or A’s built-in capital gains tax, reducing that value by a 15-percent minority discount to which the parties agree, and reducing the resulting value by a lack-of- marketability discount of $28 million which the Court arrived at by giving consideration to, inter alia, A’s built-in capital gains tax and including as part of that

John M. Barnes, Donor, Petitioner T.C. Memo. 1998-413 · 1998

230.144 (1984), restricted securities eventually become freely tradeable through either registration or the passage of time. -28- 3. Conclusion--Discounts Based on the arguments of the parties and the record, we conclude that discounts for lack of marketability of 40 percent for the Home stock and 45 percent for the Rock Hill stock are approp

Robert L. Helmly, Donor, Petitioner T.C. Memo. 1998-413 · 1998

230.144 (1984), restricted securities eventually become freely tradeable through either registration or the passage of time. -28- 3. Conclusion--Discounts Based on the arguments of the parties and the record, we conclude that discounts for lack of marketability of 40 percent for the Home stock and 45 percent for the Rock Hill stock are approp

Mary Anne G. Barnes, Donor, Petitioner T.C. Memo. 1998-413 · 1998

230.144 (1984), restricted securities eventually become freely tradeable through either registration or the passage of time. -28- 3. Conclusion--Discounts Based on the arguments of the parties and the record, we conclude that discounts for lack of marketability of 40 percent for the Home stock and 45 percent for the Rock Hill stock are approp

230.144(a)(1) (1989). The same securities law restrictions would have applied if decedent had at any time converted his Class B stock to Class A stock; such converted shares would also have been unregistered and restricted. As a result, the Class B stock (after conversion to unregistered Class A stock) could only have been sold by decedent to

John Van Heemst, Petitioner T.C. Memo. 1996-305 · 1996

The term “self-employment income” generally is defined as an individual’s net earnings from self-employment during any taxable year that do not exceed the contribution and benefit base provided by section 230 of the Social Security Act, 42 U.S.C.

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Ramon Reynoso, Petitioner T.C. Memo. 2013-25 · 2013
Cokes v. Commissioner 91 T.C. 222 · 1988
Foster v. Commissioner 80 T.C. 34 · 1983
Eades v. Commissioner 79 T.C. 985 · 1982
Estate of Beachy v. Commissioner 15 T.C. 136 · 1950
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