83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…0(a)(1) and (a)(1)(iv)).
2. Exemption for Objecting Entities Based on Moral Convictions (45 CFR 147.133(a))
3. Exemption for Certain Plan Sponsors (45 CFR 147.133(a)(1)(i))
a. Plan sponsors in general (45 CFR 147.133(a)(1)(i) prefatory text)
b. Nonprofit organizations (45 CFR 147.133(a)(1)(i)(A))
c. For-Profit Entities…
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…
IRCCourt RulingsSep 13, 2017
…nguard Fiduciary Trust Co. (Vanguard). It is
undisputed that petitioner received a distribution of $133,501 from Vanguard
during 2012. As of the close of that year petitioner was under 59½ years of age.
Vanguard sent the Internal Revenue Service (IRS) and petitioner a Form
1099-R, Distributions From Pensions, Annuities…
82 FR 47838 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…he reference “147.131 and 147.132” and adding in its place the reference “147.131, 147.132, and 147.133”.
§ 54.9815-2713AT
[Amended]
3. Section 54.9815-2713AT, as added elsewhere in this issue of the Federal Register
], is amended—
a. In paragraph (a)(1) by removing “or (ii)” and adding in its place “or (ii), or 45 CFR…
79 FR 56442 — Additional Rules Regarding Hybrid Retirement Plans IRCFinal Rules (FR)Sep 19, 2014
… plan years.
One commenter on the 2010 proposed regulations suggested that a special rule under the 133
1/3 percent rule of section 411(b)(1)(B) should not be provided for variable interest crediting rates that can potentially be negative. Other commenters suggested that the interest crediting rate to be used for purpo…
IRCCourt RulingsFeb 28, 2024★ strong match
” —not ours. See United
44
States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
IRCCourt RulingsFeb 9, 2023related by meaning
…)(2), 90 Stat. at 1835. Neither
petitioner nor respondent contends that this change is significant.
133
This provision was the same in the 1969 edition of the Code of Federal
Regulations and the 1971 edition of the Code of Federal Regulations.
134
The government made such an argument in Procter & Gamble Co. v.
Commissi…
IRCRegulationsSep 11, 2024
terest rates under section 417(e)(3) (that is, $68,908), the funding target for Plan P is $77,392 as of January 1, 2009. (See § 1.430(d)-1(f)(9), Example 12 for additional details.)(iii) The effective interest rate is the single interest rate that will produce the same funding target if substituted for the segment inte…
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 RulingsMar 5, 1987★ strong match
ies thereby created.
We likewise hold that sec. 220(b)(3)(A)(iv) is not applicable to disallow petitioners’ claimed IRA deductions. See note 16 supra. Since there is a complete absence in the legislative history of sec. 219 as to whether art. Ill judges were to be allowed the benefits of IRA contributions, we cannot sp…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
…ing 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (1957), relied upon by petitioner, are clearly distinguishable on their facts.
IRCRegulationsSep 9, 2016
…iod is the calendar year. Even though no single accrual rate under the J Corporation's plan exceeds 133 1/3 percent of the immediately preceding accrual rate, the J Corporation's plan does not satisfy the requirements of this subparagraph because the rate of accrual for all years of participation in excess of 10 (1 7/9…
ERISACourt RulingsJan 20, 1998
…ndents' Use of
$246,500.00
Initially, I note that the evidence does not
indicate that more than $50,392.78 of the Plan's assets were used
to purchase CD No. 328. In its penalty calculations regarding this
transaction, Complainant proceeds on the assumption that the entire
cost of CD No. 328, namely $246,500.00, was bor…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
IRCCourt RulingsFeb 18, 1981
…946), affg. a Memorandum Opinion of this Court; Dix v. Commissioner, 46 T.C. 796, 804 (1966), affd. 392 F.2d 313 (4th Cir. 1968); Kaufman’s, Inc. v. Commissioner, 28 T.C. 1179, 1184—1185 (1957); Reliable Incubator & Brooder Co. v. Commissioner, 6 T.C. 919, 926 (1946); Klein v. Commissioner, 31 B.T.A. 910, 917-919 (1934…
37 T.C. 7 — Barbourville Brick Co. v. Commissioner IRCCourt RulingsOct 9, 1961related by meaning
e distribution.
Although section 816 of the 1954 Code rather than section 115 of the 1939 Code is applicable here, the relevant language is identical. The dividend issue was raised expressly by respondent for the first time at the trial by the statement that “the amounts involved in this case are * * * a preferential o…
IRCCourt RulingsFeb 25, 1959related by meaning
ration from the service” within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners. In Mary Miller, 22 T.C. 293, affd. 226 F. 2d 618, the May Company acquired all the assets of the Strouss-Hirshberg Company in exchange for May Company stock. Three days …
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
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, 2014
…by the amount of the AIR ($500,000 − $300,000). The reduced deduction limit is then applied to O’s $133,333 of DDR attributable to services performed by O in L’s 2017 taxable year that is paid in 2018. Because $133,333 does not exceed that reduced deduction limit of $200,000, the $133,333 is deductible for 2018. The de…
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …