§231

1994) (finding that the federal judicial disability statute is not “in the nature 5 of” a workmen’s compensation act because it does not distinguish between disabilities related versus unrelated to work activities); Take v. Commissioner, 804 F.2d 553, 558 (9th Cir. 1986) (finding that the municipal disability benefits ordinance for police officers and firefighters is not “in the nature of” a workmen’s compensation act because the ordinance required no specific evidence that certain illnesses we

§§ 231–231v), a railroad employee and his spouse may be entitled to receive certain types of annuity benefits from the RRB, including Tier 1, Tier 2, and supplemental annuity benefits as described above. Absent disability, no benefits are paid to the employee by the RRB until he reaches age 62, reaches age 60 and completes 30 years of service, or re

2085, 2173–80 (amending the research credit and renumbering its section as section 41). 6 [*6] permitted taxpayers to currently deduct certain business-related research and experimental expenditures, rather than capitalizing them. For amounts paid or incurred in tax years beginning after 2021, section 174 generally requires capita

2085, 2173–80, the Omnibus Budget Reconciliation Act of 1989 (OBRA 1989), Pub. L. No. 101-239, § 7110, 103 Stat. 2106, 2322–26, the Small Business Job Protection Act of 1996 (SBJPA), Pub. L. No. 104-188, § 1204, 110 Stat. 1755, 1773–75, and the Tax Relief and Health Care Act of 2006 (TRHCA), Pub. L. No. 109-432, §§ 104, 123(a), 120

231(a), 83 Stat. at 578. Before the addition ofsubsection (d), there was no provision for waiving the 39-week requirement imposed by section 217(c)(2). Section 217(d)(1) was added to eliminate the hardship that arises when an employee "is prevented from satisfying the test by circumstances beyond his control, such as his death or an unexpected

231i(c) (2012)); Railroad Unemployment Insurance Act Amendments, ch. 842, sec. 11, 54 Stat. at 1096 (1940) (codified as amended at - 46 - 45 U.S.C. sec. 352(d) (2012 & Supp. I 2013)) (all using the phrase "against equity or good conscience"); see also 5 U.S.C. secs. 5584(a), 8346(b), 8470(b) (2012); 10 U.S.C. secs. 1442, 1453(b)(2) (2012); 37

231(d)(2), 100 Stat. 2085 at 2173-2180. - 8 - research expenses". The formerprovisions, in sections 44F(c) and 30(c), respectively, defined "base period research expenses" as the average ofQREs for the three years preceding the taxable year at issue. When Congress reenacted and redesignated the credit in 1986 as section 41, then section 41(a)

e prescribed therefor, each licensee shall pay to the .department of taxation the . tax imposed by this chapter-,',required to be shown by the return . , Penalties and interest shall be added to and become a part .of the tax, when and as provided by section 231-39 . § 245-7 Determination of tax ;'addit(cid:127)ional -assessments, credits, and'refunds . (a) As soon as practicable after each return shall have been filed, the department of taxation shall cause it. to be'examined and shall .compute

231(d)(2), 100 Stat. 2173-2180. In connection with the latter reenactment, Congress indicated that the “purpose of enacting the credit [in 1981] was to encourage business firms to perform the research necessary to increase the innovative qualities and efficiency of the U.S. economy.” H. Rept. 99-426, at 177 (1985), 1986-3 C.B. (Vol. 2) 1, 177;

231a(a)(1)(v), by the RRB. The RRB found that January 31, 1998, was the onset date of petitioner’s disability, entitling her to disability annuity payments as of July 1, 1998. Petitioner received $14,970.84 in annuity payments from the RRB during the 2001 taxable year. For that year, petitioner 2 The Railroad Retirement Board is an independent

1076, and the Revenue Act of 1921, ch. 136, sec. 231, 42 Stat. 253, provided an exemption from income tax for building and loan associations but did not further define such an entity. The U.S. Supreme Court accepted the State’s classification of a building and loan association in the absence of a definition in the Federal statute

231(a)(1) (1994). Petitioners have not presented any evidence regarding Mr. Howle’s length of service. We thus conclude that Mr. Howle was not eligible for retirement until he turned 62 on October 31, 1997, and that the railroad retirement benefits petitioners received in 1997 were on account of disability until such date. We have found no pro

231(1) Absent a treaty provision to the contrary, the shareholder credit is not available to nonresidents of the United Kingdom. See id. The United States and the United Kingdom entered into the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains and Three Proto

Absent a treaty provision to the contrary, the shareholder credit is not available to nonresidents of the United Kingdom. See id. The United States and the United Kingdom entered into the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains and Three Prot

324, 496. The language of section 1272(a)(1), enacted by the Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 41, 98 Stat. 494, 531, is substantively identical to former section 1232A(a)(1). - 5 - year the amount of the accrued discount allocable to the portion of the taxable year in which he or she held such debt instrument.

229, 268. This section was entitled "Credit 5 Congress enacted sec. 44D in 1980. See Crude Oil Windfall Profit Tax Act of 1980, Pub. L. 96-223, sec. 231(a), 94 Stat. 268. In the Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 471(c)(1), 98 Stat. 826, Congress redesignated sec. 44D as sec. 29. - 66 - For Producing Fuel From A