REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…s follows: general rules on qualified and nonqualified benefits in cafeteria plans (new proposed §1.125-1), general rules on elections (new proposed §1.125-2), general rules on flexible spending arrangements (new proposed §1.125-5), general rules on substantiation of expenses for qualified benefits (new proposed §1.125…
Notice 2020-33 — This notice increases the $500 limit for unused amounts remaining in a health FSA that may be carried over into the following year by making the carryover amou… IRCNoticesMay 26, 2020
under § 125(i)). B. Deadline for a written § 125 cafeteria plan amendment to implement indexing of maximum carryover amount for 2020 (or a later year) As a general rule, an amendment to a § 125 cafeteria plan to increase the carryover limit must be adopted on or before the last day of the plan year from which amounts m…
Notice 2014-55 — Notice 2014–55 expands the application of the permitted change rules for health coverage under a § 125 cafeteria plan and addresses two specific situations in … IRCNoticesOct 6, 2014
end to modify the regulations under § 125 consistent with the provisions of this notice, but taxpayers may rely on this notice immediately.
BACKGROUND Section 125(d)(1) defines a cafeteria plan as a written plan maintained by an employer under which all participants are employees, and all participants may choose among …
IRCCourt RulingsNov 17, 2016related by meaning
etitioner neglected to apply the correct method to reduce the maximum
benefits under section 415(b)(2)(C) for a retirement age before age 62 under its plan, where the plan did not provide for forfeiture of the participant's benefits at
death. By virtue of this error, portions of petitioner's contributions to the plan
d…
ERISADOL Technical ReleasesSep 13, 2013
… 43957 (August 6, 2007) (proposed regulations; to be codified, in part, once final, at 26 C.F.R. §1.125-5); Code §§ 105(b) and 106(f). Contributions to a health FSA offered through a cafeteria plan satisfying the requirements of Code § 125 (a Code § 125 plan) do not result in gross income to the employee. Code § 125(a)…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
IRCCourt RulingsMar 5, 2018related by meaning
¹² The Commissioner here also doesn't seek to redetermine income tax, but
only because the statute of limitations has run--he says if it hadn't, he'd redetermine the income tax too. We previously decided this was enough of a
distinction from Hellweg to let these cases go forward on the excise-tax issue
alone. Mazzei v…
IRCCourt RulingsAug 30, 1993related by meaning
ding standard under section 412(d) but chose not to do so. We sustain respondent's determination of petitioner's section 4971(a) excise tax liability. FYE 1987 Employer ReversionSection 4980(a) imposes a 10-percent tax on the amount of any employer reversion from a qualified plan. The term "employer reversion" is defin…
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…
IRCCourt RulingsMay 27, 2004related by meaning
is liable for the
second-tier excise tax under section 4975(b). We note, however,
- 19 -
that sections 4961(a) and 4963(e)(1) generally allow for the abatement of a second-tier excise tax if the prohibited
transaction giving rise thereto is corrected within 90 days after
our decision sustaining the tax becomes final. …
IRCCourt RulingsMay 20, 1976related by meaning
ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment.
SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
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…
IRCCourt RulingsMar 6, 2001related by meaning
claim to a pension plan
contribution deduction on that ground forecloses her claim that
she is entitled to an above-the-line Schedule C deduction for legal fees, rather than the itemized deduction subject to the 2percent limitation of section 67 that respondent allowed in the
statutory notice.
To give effect to all the…
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 …
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023related by meaning
U.S.C. 1108), 112 Stat. 2061; 25 U.S.C. 1647b.
2. Section 890.114 is amended by revising paragraph (a) to read as follows:
§ 890.114
Surprise billing. (a) A carrier must comply with requirements described in 26 CFR 54.9816-3, 54.9816-3T through 54.9816-6T, 54.9816-6A, 54.9816-6, 54.9816-8T, 54.9816-8, 54.9817-1T, 54.98…
IRCCourt RulingsFeb 22, 1999related by meaning
112 T.C. No. 6
UNITED STATES TAX COURT
GIDEON L. MEDINA AND CORAZON P. MEDINA, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18999-97. Filed February 22, 1999.
H and W, who were both disqualified persons within
the meaning of sec. 4975, I.R.C., borrowed $340,000
from the qualified pension plan…
IRCCourt RulingsJul 13, 2015related by meaning
claimed medical transportation expenses and that he falls under the
exception in section 72(t)(2)(B). As discussed supra Part II.A, petitioner is not entitled to deduct his claimed medical transportation expenses under section
213(a). Therefore, he does not fall under the exception in section 72(t)(2)(B) and
he is lia…
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…
IRCRegulationsDec 30, 2016
(b) (b) Contributions made through a section 125 cafeteria plan. Employer contributions to employees' HSAs are made through a section 125 cafeteria plan and are subject to the section 125 cafeteria plan nondiscrimination rules and not the comparability rules if under the written cafeteria plan, the employees have the r…
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…