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Sections 264, 265, and 911 would continue to apply a forward-disallowance rule for deductions relating to excludible life insurance, tax-exempt income, and excluded foreign source earned income.
from issues of misallocation of receipts to the excludible category,
If the award is for pain and suffering, related to the back injury, the amount received is excludible.
Given the absence of guidance in the statute and regulations, the relevant criteria for determining whether a nonshareholder payment is excludible have been developed in the courts, including the Supreme Court on several occasions.
Consequently, it appears that gain from an elective deemed sale of a principal residence may not be excludible under IRC Sec.
In this situation, the excludible amount of interest is based upon a fraction which must be applied to the total interest income.
The earnings from the fund are excludible from income, including capital gains, interest, and dividends.
Related to food and beverages excludible as de minimis fringe benefits (section 274(n)(2)(B)).
162 or 167 to be allowable, those requirements apply in determining whether a property or service is excludible as a working condition fringe benefit.
Helvering (35-1 USTC [paragraph] 9043), 293 US 465,469 (1935), argued the $129,000 of compensation John returned to JMA was excludible from gross income because the couple was entitled to structure their transactions to pay the least amount of federal income tax.
General welfare exclusion: A private letter ruling involved whether funds received by individuals from a county for various programs--including a job training one and one available to county employees--were excludible under the general welfare exclusion to Sec.
Revenue ruling 2003-102 held that an employee's receipt of a reimbursement from an employer-sponsored health flexible spending arrangement (health FSA) under a cafeteria plan, health reimbursement arrangement or other employer health plan for over-the-counter (OTC) drugs is excludible from gross income under IRC section 105(b); however, amounts an employee pays for dietary supplements are not reimbursable or excludible, nor can the individual deduct such costs as section 213 medical expenses.