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84 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac…
    IRCProposed Rules (FR)Proposed Jul 12, 2023
    onsumer notice would be revised and moved to 45 CFR 148.220(b)(4)(iii). See section III.B.1.d of this preamble for more details. Back to Citation 165.  As discussed further in section III.B.1.b of this preamble, HHS proposes other amendments to the new proposed paragraph (b)(4)(ii) at 45 CFR 148.220 to capture the prop…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …il, 3M Company, and 3M IPC for the 2006 year is $165,783 (equal to $4,283,153 minus an offset of $4,117,370 for unreimbursed research - and -develop ment expenses (R & D offset )) . We interpret the term “minimum section 482 adjustment” to be the minimum section 482 adjustment that would be made if petitioner were to p…
  4. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987★ strong match
    ies thereby created. We likewise hold that sec. 220(b)(3)(A)(iv) is not applicable to disallow petitioners’ claimed IRA deductions. See note 16 supra. Since there is a complete absence in the legislative history of sec. 219 as to whether art. Ill judges were to be allowed the benefits of IRA contributions, we cannot sp…
  5. 76 FR 52442 — Summary of Benefits and Coverage and the Uniform Glossary
    IRCProposed Rules (FR)Proposed Aug 22, 2011
    …l Managers 75.32 0.5 38 0.5 38 0.5 38 Attorneys 85.44 0.5 43 0.5 43 0.5 43 Total per issuer/TPA   4 220 4 220 4 220 Total for all issuers/TPAs   1100 61,000 1800 100,000 550 31,000 Task 2—Equivalent Costs for Distributing SBCs   Hourly wage rate Hours per SBC
  6. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  7. Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par…
    IRCRevenue ProceduresModified Aug 2, 2021
    …219 .01 User fees 219 PART VI. CORRECTION ON AUDIT (AUDIT CAP) SECTION 13. DESCRIPTION OF AUDIT CAP 220 .01 Audit CAP requirements 220 .02 Payment of sanction 220 .03 Additional requirements 220 .04 Failure to reach resolution 220 .05 Effect of closing agreement 220 .06 Other procedural rules 220 SECTION 14. AUDIT CAP …
  8. Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of …
    IRCRevenue ProceduresModified Dec 29, 2025
    …9 .02 Steps for exhausting administrative remedies 219 .03 Applicant’s request for § 7805(b) relief 220 .04 Interested parties 220 .05 Deemed exhaustion of administrative remedies 220 .06 Service must have reasonable time to act on appeal 220 .07 Service must have reasonable time to act on request for § 7805(b) relief …
  9. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  10. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    …dified retroactively 219 .07 Will not apply to a similar transaction in same year or any other year 220 .08 Retroactive effect of revocation or modification applied to a continuing action or series of actions 220 .09 May be retroactively revoked or modified if the transaction is completed without reliance on the letter…
  11. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
  12. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …edicare-Medicaid Plans, and Denominational Health Plans. Interaction of Final Rules With 45 CFR 156.220 The Departments recognize that health insurance issuers offering group or individual health insurance coverage as QHPs through an Exchange are already subject to reporting requirements under 45 CFR 156.220 that imple…
  13. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984
    …(8), 408(d)(3), or 409(b)(3)(c)), over (B) the amount allowable as a deduction under section 219 or 220 for such contributions, and (2) the amount determined under this subsection for the preceding taxable year reduced by the sum of— (A) the distributions out of the account for the taxable year which were included in t…
  14. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  15. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    section 1041. See Balding v. Commissioner, 98 T.C. 368 (1992). In order to implement the views expressed herein, An appropriate order will be issued. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules o…
  16. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    …ed exhaustion of administrative remedies 219 .06 Service must have reasonable time to act on appeal 220 .07 Service must have reasonable time to act on request for § 7805(b) relief 220 SECTION 23. WHAT EFFECT WILL A DETERMINATION LETTER HAVE? 220 .01 May be relied on subject to limitations 220 .02 Scope of reliance on …
  17. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  18. Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 2, 2024
    …e must be given 219 .03 Content of notice 219 .04 Information to be available to interested persons 220 .05 Information described in § 6110(c) should not be included 220 .06 Section 20B is not applicable to plan sponsors of governmental plans 220 PART IIC. PROCESSING DETERMINATION LETTER REQUESTS SECTION 21. HOW DOES E…
  19. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  20. Rev. Proc. 2016-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the …
    IRCRevenue ProceduresJan 4, 2016
    …quired for terminating plan 219 SECTION 13. GROUP TRUSTS 219 .01 Scope 219 .02 Required information 220 .03 Forms 220 SECTION 14. AFFILIATED SERVICE GROUPS; LEASED EMPLOYEES 220 .01 Scope 220 .02 Employer must request the determination under § 414(m) or § 414(n) 220 .03 Forms 221 .04 Employer is responsible for determi…