§77 — Commodity credit loans
79 citing cases
Statute Text — 26 U.S.C. §77
Amounts received as loans from the Commodity Credit Corporation shall, at the election of the taxpayer, be considered as income and shall be included in gross income for the taxable year in which received.
If a taxpayer exercises the election provided for in subsection (a) for any taxable year, then the method of computing income so adopted shall be adhered to with respect to all subsequent taxable years unless with the approval of the Secretary a change to a different method is authorized.
Treasury Regulations
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Treas. Reg. §1.77-1Election to consider Commodity Credit Corporation loans as income
A taxpayer who receives a loan from the Commodity Credit Corporation may, at his election, include the amount of such loan in his gross income for the taxable year in which the loan is received. If a taxpayer makes such an election (or has made such an election under section 123 of the Internal Revenue Code of 1939 or under section 223(d) of the Revenue Act of 1939 (53 Stat. 897)), then for subsequent taxable years he shall include in his gross income all amounts received during those years as loans from the Commodity Credit Corporation, unless he secures the permission of the Commissioner to change to a different method of accounting. Application for permission to change such method of accounting and the basis upon which the return is made shall be filed with the Commission of Internal Revenue, Washington, D.C. 20224, within 90 days after the beginning of the taxable year to be covered by the return.
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Treas. Reg. §1.77-2Effect of election to consider commodity credit loans as income
(a) If a taxpayer elects or has elected under section 77, section 123 of the Internal Revenue Code of 1939, or section 223(d) of the Revenue Act of 1939 (53 Stat. 897), as amended, to include in his gross income the amount of a loan from the Commodity Credit Corporation for the taxable year in which it is received, then—
(1) No part of the amount realized by the Commodity Credit Corporation upon the sale or other disposition of the commodity pledged for such loan shall be recognized as income to the taxpayer, unless the taxpayer receives an amount in addition to that advanced to him as the loan, in which event such additional amount shall be included in the gross income of the taxpayer for the taxable year in which it is received, and
(2) No deductible loss to the taxpayer shall be recognized on account of any deficiency realized by the Commodity Credit Corporation on such loan if the taxpayer was relieved from liability for such deficiency.
(b) The application of paragraph (a) of this section may be illustrated by the following example:
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Treas. Reg. §1.77-2(a)If a taxpayer elects or has elected under section 77, section 123 of the Internal Revenue Code of 1939, or section 223(d) of the Revenue Act of 1939 (53 Stat.
If a taxpayer elects or has elected under section 77, section 123 of the Internal Revenue Code of 1939, or section 223(d) of the Revenue Act of 1939 (53 Stat. 897), as amended, to include in his gross income the amount of a loan from the Commodity Credit Corporation for the taxable year in which it is received, then—
(1) No part of the amount realized by the Commodity Credit Corporation upon the sale or other disposition of the commodity pledged for such loan shall be recognized as income to the taxpayer, unless the taxpayer receives an amount in addition to that advanced to him as the loan, in which event such additional amount shall be included in the gross income of the taxpayer for the taxable year in which it is received, and
(2) No deductible loss to the taxpayer shall be recognized on account of any deficiency realized by the Commodity Credit Corporation on such loan if the taxpayer was relieved from liability for such deficiency.
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Treas. Reg. §1.77-2(b)§1.77-2(b)
The application of paragraph (a) of this section may be illustrated by the following example:
79 Citing Cases
§ 77b(a)(15) (2006); 17 C.F.R. § 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 ass
§ 77c(a)(11)), and Securities & Exchange Commission (SEC) Rule 147, 17 C.F.R. § 230.147 (2024). 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 resi
§ 77q(a)], Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)], and Rule 10b- 5(a) and (c) promulgated thereunder [17 C.F.R. § 40.10b-5(a) and (c)]; b) orders Defendant to pay disgorgement in the amount of $411,421.98, plus prejudgment interest thereon in the amount of $27,203.92; and c) orders Defendant t
77d(a)(5) (2016)); see generally Wright v. Nat'l Warranty Co., 953 F.2d 256, 259- 60 (6th Cir. 1992), and that they cannot sell them unless the shares got registered or an exception to registration applies. But the record also shows that Gastar was publicly traded--the parties stipulated to Gastar's share-price history and introduced Gastar's
77d(a)(5) (2016)); see generally Wright v. Nat'l Warranty Co., 953 F.2d 256, 259- 60 (6th Cir. 1992), and that they cannot sell them unless the shares got registered or an exception to registration applies. But the record also shows that Gastar was publicly traded--the parties stipulated to Gastar's share-price history and introduced Gastar's
77b(a)(15) (2006); 17 C.F.R. sec. 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 asse
77b(a)(15) (2006); 17 C.F.R. sec. 230.501(a) (2006). Variable life insurance is a form of cash value insurance. Under traditional cash value insurance, the insured 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 as
77-112 (1996 & Supp. 2000). Assessed valuation may be used to corroborate fair market value determined under the three traditional approaches. See N. Trust Co. v. Commissioner, supra. Here, the Antelope County assessor determined that the assessed value of the subject property for 1998 was $70,424. The assessment took into account physical dep
77-112 (1996 & Supp. 2000). Assessed valuation may be used to corroborate fair market value determined under the three traditional approaches. See N. Trust Co. v. Commissioner, supra. Here, the Antelope County assessor determined that the assessed value of the subject property for 1998 was $70,424. The assessment took into account physical dep
Simultaneously with his signing of the section 83(b) election for the 1979 options, Henry was provided with a copy of a letter from IMED. - 9 - Dear Option Holder: Congratulations on your recent stock option. The enclosed election, which is necessary to provide for capital gain treatment upon ultimate stock sale by you, should be
77a (1933) and were not traded on an established securities market. At the time of purchase, it was contemplated that the Citicorp Notes would be sold at the end of the month. Indeed, arrangements to sell the notes were already well underway. In several meetings beginning in late October, Pepe and other Merrill representatives discussed a prop
77-b(6) (1986), provides as follows: "Where * * * an employee fails to return [an] excess advance * * * the municipality shall deduct the amount of such unreturned excess advance from the salary or other money owed the * * * employee by the municipality." - NEXTRECORD - connection with his official duties. Accordingly, in late September or ea