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49 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …provision to persons not similarly situated or to dissimilar circumstances. (2) The provisions in § 149.100 are intended to be severable from the provisions in §§ 149.140, 149.510, and 149.530, from any grant of forbearance from removal resulting from this subpart, and from any provision referenced in §§ 149.140, 149.5…
  2. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    ertified IDR entities are required to continue to comply with the corresponding section of § 149.510 in effect prior to June 4, 2026 (i) Severability. (1) Any provision of this section held to be invalid or unenforceable by its terms, or as applied to any person or circumstance, will be construed so as to continue to g…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
  4. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
    IRCProposed Rules (FR)Proposed Sep 16, 2021
    . 116-260, 134 Stat. 2852). * * * * * 15. Section 149.20 is amended by revising paragraph (a)(1) to read as follows: § 149.20 Applicability. (a) * * * (1) The requirements in subparts B, C, and D of this part apply to group health plans and health insurance issuers offering group or individual health insurance coverage…
  5. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    s degree of essentiality and in accordance with reports from the Income Tax Division and the General Management of the National Treasur y. LUCAS LOPES File n ˚ 9413- 59. (Official Gazette, May 29, 1959). The English translation of Exhibit 30 - J (Portaria 314/70) is: Ordinance/MF n˚ 314/70. Includes the 2nd Group -- p …
  6. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …d 54.9822-1T; 29 CFR 2590.716-3 through 2590.716-8, 2590.717-1, 2590.717-2 and 2590.722; and 45 CFR 149.30, 149.110 through 149.140, 149.310, 149.510, and 149.520, in the same manner as such provisions apply to a group health plan or health insurance issuer offering group or individual health insurance coverage, subjec…
  7. 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 .
  8. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019related by meaning
    ents was this estimate, to which respondent reserved an objection on grounds of relevance and authenticity. We overrule respondent's objection. - 38 - noncorporate taxpayers to deduct losses on the sale or exchange of capital assets to the extent of the gain from such sales or exchanges, plus the lower of: (1) $3,000 o…
  9. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    applies only to the extent that it fits within the flush language or one of the referenced exceptions. - 106 - E. Reasonable Cause 1. Section 6662(a) a. Overview An accuracy-related penalty under section 6662(a) is not appropriate in a case where a taxpayer demonstrates that reasonable cause existed for an underpaymen…
  10. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  11. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    …2590.716-6, 2590.716-8, 2590.717-1, 2590.717-2, 2590.722, 2590.725-1 through 2590.725-4; and 45 CFR 149.30, 149.110 through 149.140, 149.310, 149.510 and 520, and 149.710 through 149.740 in the same manner as such provisions apply to a group health plan or health insurance issuer offering group or individual health ins…
  12. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    on or after January 1, 2022. 18. Add part 149 to read as follows: PART 149—SURPRISE BILLING AND TRANSPARENCY REQUIREMENTS Subpart A—General Provisions 149.10 Basis and scope. 149.20 Applicability. ( printed page 36971) 149.30 Definitions. Subpart B—Protections against Balance Billing for the Group and Individual Health…
  13. 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
    …e reasons set forth in the preamble, the Department of Health and Human Services amends 45 CFR part 149 as set forth below: PART 149— SURPRISE BILLING AND TRANSPARENCY REQUIREMENTS 9. The authority citation for part 149 continues to read as follows: Authority: 42 U.S.C. 300gg-111 through 300gg-139, as amended. 10. Amen…
  14. 91 FR 55462 — Federal Independent Dispute Resolution Operations; Correction
    IRCFinal Rules (FR)Aug 28, 2026
    e inadvertently omitted the word “paragraph”. On page 34077, § 149.510(c)(5)(iii)(D), we inadvertently referenced “(c)(4)(v)” rather than “(c)(5)(v)”. On page 34077, § 149.510(c)(5)(vii)(A), we inadvertently included an asterisks placeholder. On page 34077, § 149.510(c)(5)(vii)(C), we inadvertently italicized “(c)(5)(v…
  15. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    n. - 15 - To give effect to our disposition of the disputed issue, as well as petitioner's concession, see sap_rg note 2, Decision will be entered for respondent as to the income tax deficiency and for petitioner as to the accuracy-related penalty.
  16. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
  17. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    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’ …
  18. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971related by meaning
    g $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
  19. 87 FR 52618 — Requirements Related to Surprise Billing
    IRCFinal Rules (FR)Aug 26, 2022
    …eamble, the Department of Health and Human Services adopts as final the interim rules adding 45 CFR 149.140, published at 86 FR 36872 (July 13, 2021), and 45 CFR 149.510 and 149.520, published at 86 FR 55980 (October 7, 2021), with the following changes to 45 CFR part 149: PART 149—SURPRISE BILLING AND TRANSPARENCY REQ…
  20. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…