79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
Issuers
Large:
IT
75
22.0
$84
1,650
$138,584
Benefits
75
16.0
62
1,200
74,796
Legal
75
2.0
130
150
19,491
Sub-total
3,000
232,871
Medium:
IT
250
16.5 84
4,125
346,459
Benefits
250
12.0
62
3,000
186,990
Legal
250
1.5
130
375
48,728
Sub-total
7,500
582,176
Small:
IT
175
11.0
84
1,925
161,681
Benefits
175
8.0
62
1,400
87…
IRCCourt RulingsMar 5, 2018related by meaning
nt determined
excise tax deficiencies for Angelo and Mary Mazzei for 2002-07, and additions to
tax under section 6651(a)(1) and (2):¹
Additions to tax Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)
2002 $6,637 $1,493 $1,659
2003 9,408 2,116 2,352
2004 10,523 2,367 (¹)
2005 11,349 2,553 (¹)
2006 13,759 3,095 (¹)
2007 1…
75 FR 42605 — Increase in Tax Rates on Tobacco Products and Cigarette Papers and Tubes; Floor Stocks Tax on Certain Tobacco Products, Cigarette Papers, and Cigarette Tubes; … IRCFinal Rules (FR)Jul 22, 2010related by meaning
riteria for denial, suspension, and revocation of permits, and the floor stocks tax. The temporary regulations took effect on the date of publication. In the temporary rule, TTB amended the tobacco and cigarette papers and tubes regulations in parts 40, 41, 44, and 46 to reflect the new excise tax rates, provided examp…
88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 2, 2023
…nforming edits to remove references to 45 CFR 147.133 that appear in paragraph (a)(1) of 45 CFR 147.130 and paragraph (a)(1)(iv) of 26 CFR 54.9815-2713, 29 CFR 2590.715-2713 and 45 CFR 147.130. Finally, HHS proposes to remove from 45 CFR 147.130(a)(1) references to 45 CFR 147.131 and 45 CFR 147.132. Those references al…
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
.
IRCCourt RulingsFeb 9, 2023related by meaning
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…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
78 FR 218 — Shared Responsibility for Employers Regarding Health Coverage IRCProposed Rules (FR)Proposed Jan 2, 2013
…suant to the approach initially described in Notice 2011-36, these proposed regulations would treat 130 hours of service in a calendar month as the monthly equivalent of 30 hours of service per week ((52 × 30) ÷ 12 = 130). This monthly standard takes into account that the average month consists of more than four weeks.…
86 FR 66662 — Prescription Drug and Health Care Spending IRCFinal Rules (FR)Nov 23, 2021
…coverage and fully-insured group health plans, earned premium as that term is defined in 45 CFR 158.130, excluding the adjustments specified in 45 CFR 158.130(b)(5). Premium amount means, with respect to self-funded group health plans and other arrangements that do not rely exclusively or primarily on payments of premi…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
… in 45 CFR 147.131 and 147.132. Previous versions of the regulation placed that limit in 45 CFR 147.130(a)(1), but did not reiterate it in § 147.130(a)(1)(iv). To clearly set forth the applicability of the exemptions and accommodation, the Departments adopt as final the Religious IFC language, which included the langua…
T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated … IRCTreasury DecisionsDec 6, 2021
…coverage and fully-insured group health plans, earned premium as that term is defined in 45 CFR 158.130, excluding the adjustments specified in 45 CFR 158.130(b)(5). Premium amount means, with respect to self-funded group health plans and other arrangements that do not rely exclusively or primarily on payments of premi…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
ners
We do not find that the three-prong Neonatology test has been met as to any
of Environmental's owners. As to Mr. Abramo and Mr. Brown, the record contains no information regarding any steps that they personally took to determine
their proper tax liability. The actions of Mr. Tomassetti, the point person for the
ot…
T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov… IRCTreasury DecisionsOct 6, 2014related by meaning
$300,000 of the $450,000 of AIR paid to C ($450,000 − $150,000); and I may not deduct $200,000 of the $300,000 of AIR paid to C ($300,000 − $100,000). Example 2. (i) The facts are the same as Example 1, except that C’s total AIR for 2016 is $400,000, which consists of $75,000 for services provided to K; $150,000 for se…
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
IRCPrivate Letter RulingsDec 2, 2005related by meaning
- -
- - -
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…nd (e), 3121(b)(8)(A), and 3401(a)(9).)
(24) Section 111.—See section 3.01(13), above.
(25) Section 115.—Income of States, Municipalities, Etc.—Whether the income of membership organizations established by states exclusively to reimburse members for losses arising from workmen’s compensation claims is excluded from gro…
IRCCourt RulingsJan 29, 2019related by meaning
$1,875, but that the amount is limited to $1,500 pursuant to
section 25C(b).
Petitioner introduced at trial (1) an invoice from Crums Climate Control, Inc. (invoice), dated April 28, 2009, and (2) a Certificate of Product Ratings by the
Air-Conditioning, Heating, and Refrigeration Institute (AHRI certificate) dated
Oct…
IRCCourt RulingsFeb 24, 2014
115 Stat. at 97, amended sec. 415(c)(1)(A) by increasing the dollar limit
from $30,000 to $40,000. EGTRRA sec. 611(b) is effective for years beginning after December 31, 2001. EGTRRA sec. 611(i), 115 Stat. at 100.
EGTRRA sec. 632(a)(1), 115 Stat. at 113, amended sec. 415(c)(1)(B) by
increasing the percentage limit from…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …