IRCCourt RulingsFeb 9, 2023related by meaning
........ 224
C. Generally applicable ............................................. 229
D. Not part of commercial transaction ..................... 229 E. Exhaustion of remedies ........................................ 229
F. Restriction on payment in any form .................... 230
G. Circumvention or violation of re…
84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…participation in health care sharing ministries qualify as medical care expenses under Code section 213(d). An HRA, including an individual coverage HRA, generally may reimburse expenses for medical care, as defined under Code section 213(d), of an employee and certain members of the employee's family. Under Code secti…
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…against a list of items, the purchase of which qualifies as expenses for medical care under section 213(d) (including nonprescription medications). (ii) The section 213(d) medical expenses are totaled and the merchant’s or payment card processor’s system approves the use of the card only for the amount of the section 2…
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
…axpayer to reimburse the taxpayer for expenses incurred for the medical care (as defined in section 213(d)) of the taxpayer, the taxpayer's spouse, the taxpayer's dependents (as defined in section 152, determined without regard to subsections (b)(1), (b)(2), and (d)(1)(B) thereof) (dependents), and any child of the tax…
Rev. Proc. 2015-6 — 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 2, 2015
AFFILIATED SERVICE GROUPS; LEASED EMPLOYEES
213
.01 Scope
213
.02 Employer must request the determination under § 414(m) or § 414(n)
213
.03 Forms
213 .04 Employer is responsible for determining status under § 414(m) and § 414(n)
213
.05 Pre-approved plans
213
.06 Required information for § 414(m) determination
213
.07…
IRCCourt RulingsMay 11, 2006
…cted under
section 162(1) would potentially be allowable to petitioner as a deduction under section 213; namely, to the extent of $3,093.
A further limitation however, under section 213 must also be
considered. Medical expenses and health insurance premiums are
allowable as a deduction from income under section 213 onl…
IRCCourt RulingsOct 9, 1997related by meaning
ent with the intent of
DEFRA, and because it permissibly fills a gap created by sections
419 and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is
not impermissibly broader than sections 419 and 419A and,
accordingly, we hold that it is valid. Chevron…
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
…ify interested persons
212
.02 Comments by interested persons
212
.03 When comments are deemed made
213
.04 Section 19B is not applicable to plan sponsors of governmental plans
213
SECTION 20A. WHAT ARE THE GENERAL RULES FOR NOTICE TO INTERESTED PARTIES (QUALIFIED PLANS ONLY)?
213
.01 Notice to interested parties
213
.…
Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Dec 30, 2024
…ies
211
.03 Requests for DOL to submit comments
212
.04 Right to comment if DOL declines to comment
213
.05 Confidentiality of comments
213
.06 Availability of comments
213
.07 When comments are deemed made
213
SECTION 19B. WHAT NOTICE REQUIREMENTS APPLY TO INTERESTED PERSONS (§ 403(b) PLANS ONLY)?
213
.01 Requirement …
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 RulingsJul 14, 2005related by meaning
…rally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (1992),
affd. 16 F.3d 75 (5th Cir. 1994). "Issues considered in a Rule
155 proceeding are limited to 'purely mathematically generated
computational items'." Id. at 124.
In support of petitioner's argument that the Co…
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…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
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…
IRCCourt RulingsJul 22, 1980
…ion to its profit-sharing trust. In his notice of deficiency, respondent disallowed the claimed $16,123 deduction and explained that— (a)(1) The deduction claimed for contributions to your profit-sharing plan for the taxable year ended December 31, 1974 in the amount of $16,123.00 is not allowed because it has been det…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
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
…rence
212
.19 How to request status conference
212
SECTION 7. WHEN DETERMINATION LETTERS ARE ISSUED
213
.01 Requesting Determination Letters
213
.02 Forms
213
.03 Off-Cycle Applications
213
.04 Application must include copy of plan and amendments
213
.05 Restatements required
214
.06 Controlled group elections pursuant…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsOct 9, 1990related by meaning
o. v. Commissioner, 30 T.C. 10, 22-23 (1958), affd. 267 F.2d 853 (7th Cir. 1959); Times Publishing Co. v. Commissioner, 13 T.C. 329, 335 (1949), affd. per curiam 184 F.2d 376 (3d Cir. 1950). Section 23(p) was reenacted as section 404 in the 1954 Code in essentially the same form. Don E. Williams Co. v. Commissioner, 42…
IRCCourt RulingsJun 9, 2005
hat the expenses exceed 7.5
percent of the taxpayer’s adjusted gross income. See sec.
213(a). Medical care expenses include amounts paid for insurance premiums. See sec. 213(d)(1)(D). To substantiate medical and
dental expenses under section 213, a taxpayer must provide the
name and address of each person to whom payme…