145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015★ strong match
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
IRCCourt RulingsJul 14, 2005related by meaning
…e. Congress has explicitly
recognized that only one taxpayer should be subject to
the tax. H. Rept. 1447, 87th Cong., 2d Sess. (1962),
1962-3 C.B. 405, 429; see also Treas. Reg. § 1.2742(f)(2)(iv)(a). Respondent's computations in the
Notices of Deficiency fail to take that double payment
of tax into account.
At the tim…
IRCProposed Rules (FR)Proposed May 13, 2026
… adjusted for medical inflation in this example, medical inflation is calculated by subtracting 587.144 (the overall medical care component of the CPI-U (unadjusted) for December 2025) from 625.522 (the overall medical care component of the CPI-U (unadjusted) published by the Department of Labor for December of the pre…
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
8 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
9. The authority citation for part 144 continues to read as follows: Authority: 42 U.S.C. 300gg through 300gg–63, 300gg–91, 300gg–92, and 300gg– 111 through 300gg–139, as amended.
10. Section 144.103 is amended by revising the definition …
IRCCourt RulingsFeb 9, 2023★ strong match
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 …
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
h below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
12. The authority citation for part 144 is revised to read as follows:
Authority: 42 U.S.C. 300gg through 300gg-63, 300gg-91, 300gg-92, and 300gg-111 through 300gg-139, as amended.
13. Section 144.101 is amended by:
a. Redesignating paragraphs (d) and…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
… stated in the preamble, the Department of Health and Human Services proposes to amend 45 CFR parts 144, 148, 149, and 150 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
7. The authority citation for part 144 continues to read as follows:
Authority:
42 U.S.C. 300gg through 300gg-63, 300…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
83 FR 54420 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCProposed Rules (FR)Proposed Oct 29, 2018
… stated in the preamble, the Department of Health and Human Services proposes to amend 45 CFR parts 144, 146, 147, and 155 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
15. The authority citation for part 144 is revised to read as follows:
Authority:
42 U.S.C. 300gg through 300gg-63, 3…
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
… stated in the preamble, the Department of Health and Human Services proposes to amend 45 CFR parts 144, 146, and 148 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
10. The authority citation for part 144 continues to read as follows:
Authority:
42 U.S.C. 300gg through 300gg-63, 300gg-9…
T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua… IRCTreasury DecisionsMar 7, 2016related by meaning
…tion, the regulations update certain mailing addresses listed in regulations under sections 897 and 1445. Specifically, these regulations modify 26 CFR 1.897–2, 26 CFR 1.897–3, 26 CFR 1.1445–1, 26 CFR 1.1445–2, 26 CFR 1.1445–3, 26 CFR 1.1445–4, 26 CFR 1.1445–5, 26 CFR 1.1445–6, and 26 CFR 1.1445–11T.
T.D. 9752 T.D. 975…
84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR parts 144, 146, 147, and 155 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
16. The authority for part 144 is revised to read as follows:
Authority:
42 U.S.C. 300gg through 300gg-63, 300gg-91, …
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…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…d mean, irrespective of the State, one of the following:
The individual market, as defined in45 CFR 144.103 (other than short-term, limited-duration insurance or individual health insurance coverage that consists solely of excepted benefits).
The large group market, as defined in45 CFR 144.103 (other than coverage that…
IRCCourt RulingsJan 3, 2011related by meaning
s, earnings, and reasonable charges) pursuant
tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not :
rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant
to Rev. Proc . 2005-25, lsupra.
Held, further, P must include in his gross income
the excess contributiorls pursuan…
81 FR 75316 — Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance IRCFinal Rules (FR)Oct 31, 2016
…the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR parts 144, 146, 147, and 148 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
11. The authority citation for part 144 continues to read as follows:
Authority:
Secs. 2701 through 2763, 2791, and 2…
79 FR 10296 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCFinal Rules (FR)Feb 24, 2014
… reasons set forth in the preamble, the Department of Health and Human Services amends 45 CFR parts 144, 146, and 147 as set forth below:
( printed page 10313)
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
23. The authority citation for part 144 continues to read as follows:
Authority:
Secs. 2701 through …
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
.
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
…t forth in the preamble, the Department of Health and Human Services proposes to amend 45 CFR parts 144, 146, and 147 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
25. The authority citation for part 144 continues to read as follows:
Authority:
Secs. 2701 through 2763, 2791, and 2792 o…
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR parts 144, 146, and 148 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
9. The authority citation for part 144 continues to read as follows:
Authority:
42 U.S.C. 300gg through 300gg-63, 300gg-91…