IRCRegulationsDec 30, 2016
…se of F's claims experience. (ii) Conclusion. See Example 1 in 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) for a conclusion that the issuer does not violate the provisions of 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) similar to the provisions of this paragraph (c)(2) because the issuer blends the rate so that t…
IRCCourt RulingsAug 13, 1990★ strong match
hould prevail on the substantive issues as a matter of law. Rule 121(b); Naftel v. Commissioner, supra at 529; Espinoza v. Commissioner, supra at 416. Rule 121(d) provides that “an adverse party may not rest upon the mere allegations or denials of such party’s pleading, but such party’s response, by affidavits or as ot…
IRCCourt RulingsDec 11, 2003
121 T.C. No. 19
UNITED STATES TAX COURT
FORTUNATO J. MENDES, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16032-95. Filed December 11, 2003.
P has been continuously incarcerated since June 17,
1988. For P’s 1988 taxable year, R (1) determined a tax
deficiency based upon amounts reported on inf…
78 FR 33158 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans IRCFinal Rules (FR)Jun 3, 2013
….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996).
Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010).
8. In § 146.121, paragraph (f) is revised t…
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…
IRCCourt RulingsFeb 9, 2023related by meaning
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
IRCCourt RulingsDec 19, 1989related by meaning
ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner.
Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
IRCCourt RulingsJun 18, 1999related by meaning
1402(a). We therefore simply sustain
respondent's determination as respondent did not assert an
increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally
imposed on IRA distributions made before the taxpayer reaches age
59-1/2. See sec. 72(t). In that regard,…
IRCCourt RulingsApr 20, 2017★ strong match
…t
he did not receive these items of income or that the income he received was not
taxable. See Rule 121(d). We conclude that respondent's determinations of unreported income as set forth in the notice of deficiency are correct, and those determinations are sustained. See Hardy v. Commissioner, 181 F.3d 1002, 1004 (9th
…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
IRCCourt RulingsMar 20, 1997related by meaning
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
77 FR 70620 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans IRCProposed Rules (FR)Proposed Nov 26, 2012
….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996). Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010).
2. In § 146.121, paragraph (f) is revised t…
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008
are petitioner's and
respondent's cross-motions for summary ·judgment pursuant to Rule
121.
Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years in 1ssue.
Rule 121(a) provides that either…
IRCCourt RulingsDec 4, 2017
…onal alimony" is a class of alimony that a Tennessee court may
award. See Tenn. Code Ann. sec. 36-5-121(d)(1) through (g)(1). It terminates on
the death of he recipient. Id. sec. 36-5-121(g)(3). It is described as a sum of
money payable by a spouse for a determinate period and awarded "when the court
finds that rehabil…
IRCCourt RulingsAug 31, 2021
…ay move for summary judgment regarding all or any part of the legal issues in controversy. See Rule 121(a); Wachter v. Commissioner, 142 T.C.
140, 145 (2014). We may grant summary judgment if the pleadings, stipul ations
and exhibits, and any other acceptable materials show that there is no genuine
dispute as to any ma…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsJul 5, 1983related by meaning
so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCProposed Rules (FR)Proposed Mar 21, 2013
…, other than § 146.130 and the provisions with respect to genetic nondiscrimination (found in § 146.121(b), § 146.121(c), § 146.121(e), § 146.122(b), § 146.122(c), § 146.122(d), and § 146.122(e)) do not apply to any group health plan (and group health insurance coverage) for any plan year, if on the first day of the pl…
ERISAProposed Rules (FR)Proposed Jul 21, 2016
…age of Form 5500 Data
(2014) (available at
www.oig.dol.gov/public/reports/oa/2014/05-14-003-12-121.pdf);
U.S. Gov't Accountability Office, GAO-14-92, Private Pensions: Clarity of Required Reports and Disclosures Could Be Improved
(2013) (available at
www.gao.gov/assets/660/659211.pdf);
U.S. Gov't Accountability…
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…