IRCCourt RulingsFeb 9, 2023★ strong match
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
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 EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn.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★ strong match
…isions complying with paragraph (n) in §1.125-5. (2) Additional requirements under sections 105(h), 129, and 137. A written plan is required for self-insured medical reimbursement plans (§1.105-11(b)(1)(i)), dependent care assistance programs (section 129(d)(1)), and adoption assistance (section 137(c)). Any of these p…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…y with the Department of the Treasury. Therefore, the total cost burden for DOL is approximately $9,129 and the total cost burden for the Treasury Department is $9,129. The summary of burden for this information collection has also been provided below.
Summary of Burden
Type of Review: Revised Collection.
Agency: DOL-E…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026★ strong match
…nacting new provisions using many of the same Code section numbers as TEFRA. BBA § 1101(a), (c)(1), 129 Stat. at 625 – 37. The BBA
generally governs partnership audit and adjustment procedures for
22
partnership returns filed for partnership years beginning after
December 31, 2017. BBA § 1101(g) , 129 Stat. at 638.
Und…
IRCRegulationsSep 9, 2016
(d)(6)(ii) (ii) Sections 410(b), 401(a)(26), and 129(d)(8). For purposes of paragraph (c) of this section, relating to the separate application of sections 410(b), 401(a)(26), and 129(d)(8) to the employees of a qualified separate line of business, the determination whether an employer operates qualified separate lines…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…6
9,149
0
0
Clerical workers prepare and distribute comparative analyses upon participant request
2,129,516
0.083
177,460
65.99
11,710,585
2.79
2,477,543
Clerical workers maintain recordkeeping
2,129,516
0.083
177,460
65.99
11,710,585
0
0
Total
2,129,536
355,020
23,433,073
2,477,543
1.5. Overall Summary
84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019 ERISAFinal Rules (FR)Jan 23, 2019
… 28 U.S.C. 2461 note (Federal Civil Penalties Inflation Adjustment Act of 1990); and Pub. L. 114-7, 129 Stat 584.
§ 579.1
[Amended]
25. In the following table, for each paragraph indicated in the left column, remove the dollar amount indicated in the middle column from wherever it appears in the paragraph and add in it…
IRCCourt RulingsJul 31, 2000
…unt of $164,406. At the time of conversion, the Cgroup term policy’s conversion credit balance was $129,411.70,
and $122,941.12 of that amount ($129,411.70 x 95%) was
- 57 -
transferred to the C-group conversion UL policy for potential
IRCCourt RulingsOct 9, 1997related by meaning
nd contribution, made
during December 1986, would be deductible in 1986, because that
contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986.
Accordingly, petitioner argues, the regulation contradicts the
plain language of section 419 and is invalid. Petiti…
IRCCourt RulingsMay 29, 2002related by meaning
to the additional tax under
section 72(t) and distinguished Larotonda and Murillo on the
ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is
equally true of the distribution here.
- 5 -
To reflect the foregoing,
An appropriate order of
dismissal a…
IRCCourt RulingsJul 24, 2003related by meaning
1
Unless otherwise indicated, section references
hereafter are to the Internal Revenue Code in effect for the year
at issue.
T.C. Summary Opinion 2003-103
UNITED STATES TAX COURT
SANTOS M. AND INGRID I. CASTILLO, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4698-02S. Filed July 24, 2003.
Sant…
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…
IRCCourt RulingsDec 29, 2005related by meaning
lusion, we need not decide
respondent's contention regarding the fact that petitioner did
not receive a determination from the United States competent authority as to whether the French retirement plan generally
corresponds to a United States retirement plan or that certain
documents, including Exhibits 9-P and 12-P, a…
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
IRCCourt RulingsJun 29, 2015
…ed into a series of
agreements. Pursuant to these agreements the Summa subsidiaries paid JC Export
$129,791, $672,048, $625,438, and $810,646 on January 18, April 23, July 25,
- 7 -
[*7] and December 22, 2008, respectively.5 Summa also paid $1,083 of expenses
on behalf of JC Export and JC Holding during 2008. The Summa…
IRCRegulationsSep 9, 2016
Separate application of section 129(d)(8). [Reserved]
IRCRegulationsJan 19, 2024
…benefit. Accordingly, this single-sum payment is equal to 25% of the full single-sum amount, or $42,129. The remaining portion of the accrued benefit is 75% of the total accrued benefit, or $750 per month payable as a straight life annuity at normal retirement age. (4) To settle the remaining portion of the accrued ben…
IRCCourt RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
ERISACourt RulingsSep 29, 2026
…deadline to bring a civil action when denying benefits);
Mirza v. Ins. Adm’r of Am. Inc. , 800 F.3d 129, 136 (3d Cir. 2015) ( stating
that “29 C.F.R. § 2560.503 – 1(g)(1)(iv) requires that adverse benefit
determinations set forth any plan- imposed time limit for seeking judicial
review”); Moyer v. Metro. Life Ins. Co .…