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…
88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac… IRCProposed Rules (FR)Proposed Jul 12, 2023
…each of the conditions currently captured in 26 CFR 54.9831-1(c)(4)(ii)(A) through (C), 29 CFR 2590.731-1(c)(4)(ii)(A) through (C), and 45 CFR 146.145(b)(4)(ii)(A) through (C). If these proposed rules are finalized as proposed, the issuer would also be required to comply with the consumer notice requirements in new pro…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent.
Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
76 FR 52442 — Summary of Benefits and Coverage and the Uniform Glossary IRCProposed Rules (FR)Proposed Aug 22, 2011
…es to which are incorporated into ERISA by section 715). The preemption provisions of ERISA section 731 and PHS Act section 2724 [2] (implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a)) apply so that the requirements of part 7 of ERISA and title XXVII of the PHS Act, as amended by the Affordable Care Act, are not …
IRCCourt RulingsJul 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
85 FR 77952 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business IRCFinal Rules (FR)Dec 2, 2020
…nt threshold is consistent with the administrative exception found in the regulations under section 731 for certain investment activities.
See
section 731(c)(3)(C)(i) & § 1.731-2(e). Some commenters noted that this was not a relevant standard because section 731(c)(3)(C)(i) does not define control. Section 731 defines …
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr… IRCAnnouncementsMay 9, 2005
…2 Stat. 645 (42 USC 651 note); Secretary of Labor’s Order 1-2003, 68 FR 5374 (Feb. 3, 2003).
§ 2590.731 [Corrected]
2. Section 2590.731(c)(2)(i), the language “§2590.701-3(a)(1)(i) (for purposes of” is removed and the language “§2590.701-3(a)(2)(i) (for purposes of” is added in its place.
3. Section 2590.731(c)(2)(ii),…
79 FR 10296 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCFinal Rules (FR)Feb 24, 2014
…ng a plan as an insurance or investment company or bank, the preemption provisions of ERISA section 731 and PHS Act section 2724 (implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a)) apply so that the HIPAA requirements (including those of the Affordable Care Act) are not to be “construed to supersede any provision…
IRCRegulationsDec 30, 2016
…dbirth other than through health insurance coverage.
(e)(3) (3) Preemption provisions under section 731(a) of ERISA. See 29 CFR 2590.711(e)(3) for a rule providing that the preemption provisions contained in section 731(a)(1) of ERISA and 29 CFR 2590.731(a) do not supersede a state law if the state law is described in …
IRCCourt RulingsJul 31, 2000
…p term policy was in its first year.
The second-year premium, before any experience refund, was
$10,731.50. The policy was credited with an experience refund of
$106.08, and the Neonatology Plan paid the net premium of
$10,625.42 ($10,731.50 - $106.08). The cost of insuring Dr. Mall
for the second year was $1,814.34, a…
IRCCourt RulingsMar 11, 2020related by meaning
little more than guesswork and failed to satisfy the strict substantiation
requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan
v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section
274(d). Cons…
78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-… IRCFinal Rules (FR)Nov 13, 2013
… to the extent they did not prevent the application of MHPAEA. The preemption provisions of section 731 of ERISA and section 2724 of the PHS Act (added by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and implemented in 29 CFR 2590.731 and 45 CFR 146.143(a)) apply so that the MHPAEA requiremen…
IRCRegulationsSep 9, 2016
…ased limitation, the suspension of benefits may not reduce the beneficiary's monthly benefit below $731.38 ($750−$18.62 = $731.38). Example 4.(i) Facts. The facts are the same as Example 3, except that on the effective date of the suspension the retiree is age 71 and the retiree's contingent beneficiary is age 77. (ii)…
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
IRCRegulationsDec 30, 2016
…ing contributions— (A) A $300 contribution to each of A's and B's HSAs which are treated as section 731 distributions to A and B;(B) A $300 contribution to C's HSA in lieu of paying C the guaranteed payment directly; and(C) A $200 contribution to each of D's and E's HSAs, who are comparable participating employees.(ii)…
78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCProposed Rules (FR)Proposed Mar 21, 2013
…ng a plan as an insurance or investment company or bank, the preemption provisions of ERISA section 731 and PHS Act section 2724 (implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a)) apply so that the HIPAA requirements (including those of the Affordable Care Act) are not to be “construed to supersede any provision…
IRCProposed Rules (FR)Proposed Dec 23, 2025
… that regulate insurance, banking, or securities. Furthermore, the preemption provisions of section 731 of ERISA and section 2724 of the PHS Act (implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a)) apply so that the provisions of Part 7 of ERISA and chapter XXVII of the PHS Act (including the amendments made by th…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…