§77 — Commodity credit loans

102 cases·9 followed·5 distinguished·2 questioned·5 overruled·81 cited9% support

(a)Election to include loans in income

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.

(b)Effect of election on adjustments for subsequent years

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.

  • Treas. Reg. §Treas. Reg. §1.77-1 Election to consider Commodity Credit Corporation loans as income
  • Treas. Reg. §Treas. Reg. §1.77-2 Effect of election to consider commodity credit loans as income
  • Treas. Reg. §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.
  • Treas. Reg. §Treas. Reg. §1.77-2(b) §1.77-2(b)

102 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

Webber v. Commissioner 144 T.C. 324 · 2015

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

Steven L. & Nancy E. Archbold, Petitioner T.C. Memo. 2005-227 · 2005

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

Michael J. & Leslie A. Cain, Petitioner T.C. Memo. 2005-227 · 2005

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

Albert J. Henry, Petitioner T.C. Memo. 1997-29 · 1997

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

Alfred P. Duffy, Petitioner T.C. Memo. 1996-556 · 1996

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

Demings v. Nationwide Life Insurance 593 F.3d 486 · Cir.
Jerry L. Demings v. Nationwide Life Insurance Co · Cir.
SEC v. Hallam · Cir.
Securities & Exchange Commission v. Credit Bancorp, Ltd. 297 F.3d 127 · Cir.
Securities And Exchange Commission v. Credit Bancorp, Ltd. 297 F.3d 127 · Cir.
Greenberg v. Commissioner 62 T.C. 331 · 1974
Fotochrome, Inc. v. Commissioner 57 T.C. 842 · 1972
Monon Railroad v. Commissioner 55 T.C. 345 · 1970
Calderon-Serra v. Wilimington Trust Company 715 F.3d 14 · Cir.
L. Claire Lander, Charles M. Droz, Julian Block, and Zelda Block v. Hartford Life & Annuity Insurance Company and Hartford Life Insurance Company 251 F.3d 101 · Cir.
California Public Employees' Retirement System v. Worldcom, Inc. 368 F.3d 86 · Cir.
Thompson v. Commissioner 38 T.C. 153 · 1962
DeHaven v. Commissioner 36 T.C. 935 · 1961
Interworks Systems Inc. v. Merchant Financial Corp. 604 F.3d 692 · Cir.
Interworks Sys. Inc. v. Merchant Fin. Corp. · Cir.
California Public Employees' Retirement System v. WorldCom, Inc. 368 F.3d 86 · Cir.
Daniels v. Blount Parrish & Co. 113 F. App'x 174 · Cir.
Maloney v. Commissioner 93 T.C. 89 · 1989
Viehweg v. Commissioner 90 T.C. 1248 · 1988
Herman v. Commissioner 84 T.C. 120 · 1985
Saviano v. Commissioner 80 T.C. 955 · 1983
Gresham v. Commissioner 79 T.C. 322 · 1982
Roebling v. Commissioner 77 T.C. 30 · 1981
Horwith v. Commissioner 71 T.C. 932 · 1979
Johnson Trust v. Commissioner 71 T.C. 941 · 1979
Estate of Piper v. Commissioner 72 T.C. 1062 · 1979
Bolles v. Commissioner 69 T.C. 342 · 1977
Smith v. Commissioner 67 T.C. 570 · 1976
Cornwall v. Commissioner 48 T.C. 736 · 1967
Meyer v. Commissioner 46 T.C. 65 · 1966
Caspers v. Commissioner 44 T.C. 411 · 1965
Alleghany Corp. v. Commissioner 28 T.C. 298 · 1957
Estate of Miller v. Commissioner 24 T.C. 923 · 1955
Humpage v. Commissioner 17 T.C. 1625 · 1952
Reilly Oil Co. v. Commissioner 13 T.C. 919 · 1949
Carman v. Commissioner 13 T.C. 1029 · 1949
Henry v. Commissioner 7 T.C. 228 · 1946
Bar B Co. v. Commissioner 7 T.C. 554 · 1946
Behl v. Commissioner 7 T.C. 1473 · 1946
Plow Realty Co. v. Commissioner 4 T.C. 600 · 1945
Curtis v. Commissioner 3 T.C. 648 · 1944
Saltonstall v. Commissioner 2 T.C. 1099 · 1943
Bedford v. Commissioner 2 T.C. 1189 · 1943
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Renfro v. Unisys Corp. 671 F.3d 314 · Cir.
United States v. Luciano Pascacio-Rodriguez 749 F.3d 353 · Cir.
United States v. Tang Nguyen 758 F.3d 1024 · Cir.
Bonnie Fish v. Greatbanc Trust Company 749 F.3d 671 · Cir.
B. Belk, Jr. v. Commissioner of Internal Revenue 774 F.3d 221 · Cir.
Baltimore County v. Hechinger Liquidation Trust (In Re Hechinger Investment Co. of Delaware, Inc.) 335 F.3d 243 · Cir.
United States v. Stevens · Cir.
Starla Rollins v. Dignity Health 830 F.3d 900 · Cir.
United States v. Everett Miller 833 F.3d 274 · Cir.
State of California v. the Little Sisters of the Poor 911 F.3d 558 · Cir.
United States v. William Rand · Cir.
Malouf v. SEC. & Exch. Comm'n 933 F.3d 1248 · Cir.
Gonnella v. Securities and Exchange Commission 954 F.3d 536 · Cir.
In Re: Hechinger Investment Company of Delaware, Inc., Debtor Baltimore County, Maryland Montgomery County, Maryland Prince George's County, Maryland State of Maryland v. Hechinger Liquidation Trust Patricia A. Staiano, Trustee State of Maryland, Baltimore County, Maryland, Montgomery County, Maryland, and Prince George's County, Maryland 335 F.3d 243 · Cir.
United States v. Michael Norwood 49 F.4th 189 · Cir.
Wilson v. Commissioner 705 F.3d 980 · Cir.
Baltimore County v. Hechinger Liquidation Trust 335 F.3d 243 · Cir.
Natl Horsemen's Benevolent v. Black 107 F.4th 415 · Cir.