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  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    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…
  3. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
  4. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …iders of air ambulance services in 26 CFR 54.9816-6T(d)(2), 29 CFR 2590.716-6(d)(2), and 45 CFR 149.140(d)(2). Back to Citation 14.  26 CFR 54.9816-6T(d)(2)(i), 29 CFR 2590.716-6(d)(2)(i), and 45 CFR 149.140(d)(2)(i). Under the July 2021 interim final rules, plans and issuers are required to calculate the QPA using und…
  5. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …Review of determination letters 172 SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER? 173 .01 Scope of this section 173 .02 Scope of determination letters 173 .03 Design-based safe harbor 173 .04 Governmental plans under § 414(d) 173 .05 Church plans under § 414(e) 173
  6. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …an payment amount for the same or similar service in that geographic area, as defined in 45 CFR 149.140(a)(7), that is reflected in an independent database as defined in 45 CFR 149.140(a)(2) (had expected charges for services C or D been included in the good faith estimate, the median payment amount for the same or sim…
  7. 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
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
  8. 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
    …ules, the term “total annual spending” means incurred claims, as that term is defined in 45 CFR 158.140, excluding the adjustments specified in 45 CFR 158.140(b)(1)(i), 45 CFR 158.140(b)(2)(iv), and 45 CFR 158.140(b)(4), and including cost sharing but net of prescription drug rebates, fees, and other remuneration. Cons…
  9. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    sec. 924 to include gross receipts from export sales or commission transactions. 24The amount computed under sec. 925(a)(1) could not exceed twice the amount computed under sec. 925(a)(2)--i.e., 46% of the combined taxable income of the FSC and its related supplier from sale 1 and sale 2. Sec. 925(d). 25The FSC regulat…
  10. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    …d the request 172 .05 Pending letter ruling requests 172 .06 When to attach letter ruling to return 173 .07 How to check on status of request 173 SECTION 7. WHAT ACTIONS ARE TAKEN IF A REQUEST IS WITHDRAWN OR EMPLOYEE PLANS RULINGS AND AGREEMENTS DECLINES TO ISSUE A LETTER RULING OR DETERMINATION LETTER? 173 .01 In gen…
  11. Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20…
    IRCRevenue ProceduresJan 2, 2019
    …) 172 .05 Church plans under § 414(e) 172 .06 Tax treatment of certain contributions under § 414(h) 173 .07 Other limits on scope of determination letter 173 .08 Leased employees 173 .09 Partial terminations 173 .10 Publication 794, Favorable Determination Letter 173 SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUES…
  12. 81 FR 71019 — Electronic Notice of Liquidation
    IRCProposed Rules (FR)Proposed Oct 14, 2016
    …tion, in accordance with § 159.9(d), in addition to the notice specified in § 159.9(c)(2)(ii). PART 173—ADMINISTRATIVE REVIEW IN GENERAL 6. The general authority citations for part 173 continues to read as follows: Authority: 19 U.S.C. 66, 1501, 1520, 1624. 7. Revise § 173.4a to read as follows: § 173.4a Refund of exce…
  13. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …
  14. 81 FR 89375 — Electronic Notice of Liquidation
    IRCFinal Rules (FR)Dec 12, 2016
    …ation, in accordance with § 159.9(d), in addition to the notice specified in § 159.9(c)(2)(i). PART 173—ADMINISTRATIVE REVIEW IN GENERAL 6. The general authority citation for part 173 continues to read as follows: Authority: 19 U.S.C. 66, 1501, 1520, 1624. 7. Revise § 173.4a to read as follows: § 173.4a Refund of exces…
  15. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    …BLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS? 173 .01 In general 173 .02 Letter ruling 173 .03 Closing agreement 173 .04 Determination letter 173 .05 Opinion letter 173 .06 Oral advice 174 .07 Nonbank trustee approval letters 174 .08 Compliance statement 175 .09 Adv…
  16. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    means incurred claims, as that term is defined in 45 CFR 158.140, excluding the adjustments specified in 45 CFR 158.140(b)(1)(i), 45 CFR 158.140(b)(2)(iv), and 45 CFR 158.140(b)(4), and including cost sharing but net of prescription drug rebates, fees, and other remuneration. Consistent with the definition in 45 CFR 15…
  17. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024
    …ndent Producer and two hours for a legal professional at an insurer, resulting in an hour burden of 173,535 hours and an equivalent cost of $28.7 million.[106] Table 14—Hour Burden and Equivalent Cost Associated With the Recordkeeping Requirement Activity Year 1 Subsequent years Burden hours Equivalent burden cost Burd…
  18. Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2023
    …evenue procedure 169 .04 Updated annually 172 .05 Possible future updates related to Appeals review 173 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2022-4? 173 .01 In general 173 .02 Changes made to Revenue Procedure 2022-4 173 PART I. GENERALLY APPLICABLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PR…
  19. Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t…
    IRCRevenue ProceduresSuperseded Jan 4, 2021
    ….03 Chief Counsel 172 .04 Determination letters not issued for requests for minimum funding waivers 173 SECTION 6. WHAT ARE THE GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 173 .01 In general 173
  20. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…