84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…H employs 17 full-time employees and 10 part-time employees whose work site is in rating area 1 and 552 full-time employees whose work site is in rating area 2. For 2020, Plan Sponsor H offers its 17 full-time employees in rating area 1 a traditional group health plan and each of its 552 full-time employees in rating a…
IRCCourt RulingsAug 1, 2012★ strong match
4, 2011, but was continued on petitioners' motion so that the parties
could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on
petitioners' motion so that they could take a trip out of the country.
By notice served May 9, 201…
Treas. Reg. § 54.9802-4(f)(1)(ix) — Special Rule Allowing Integration of Health Reimbursement Arrangements (HRAs) and Other Account-Based Group Health Plans with Individual Health Insurance Cover… IRCRegulationsAug 19, 2019
…H employs 17 full-time employees and 10 part-time employees whose work site is in rating area 1 and 552 full-time employees whose work site is in rating area 2. For 2020, Plan Sponsor H offers its 17 full-time employees in rating area 1 a traditional group health plan and each of its 552 full-time employees in rating a…
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 RulingsJul 13, 2006
…uring the year 2002, petitioner, as an employee and a
participant in the pension plan, withdrew $67,552 .64 from the
plan, the proceeds of which were to fund her daughter's higher
education expenses .
On her Federal income tax return for 2002, petitioner
reported the entire amount of the pension plan withdrawal as
inco…
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
IRCCourt RulingsAug 24, 1995related by meaning
OPINION
Tannenwald, Judge:
Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
IRCCourt RulingsMar 9, 2011★ strong match
…'s qualified export sales (ADF commission payments).
ADF reported qualified export sales of $10,308,552 in
IRCCourt RulingsSep 25, 1996★ strong match
… 80 during 1980. MIT 80,
under its cash method of accounting, accordingly reported a loss
of $2,247,552. The loss consisted of the following:
Salaries and wages $456,618
Rent--independent contractors 1,673,742
Payroll taxes 35,877
Pension plan 37,109
Insurance 41,823
Professional fees 2,383
Total 2,247,552
- 21 -
7
The…
IRCCourt RulingsNov 15, 2004
…rivate foundations. See H. Rept. 91-413 (Part 1), 4, 20-21
(1969), 1969-3 C.B 202, 214; S. Rept. 91-552, 6, 28-29 (1969), 1969-3 C.B. 426, 442-443; also see Staff of the Joint Committee
on Internal Revenue Taxation, General Explanation of the Tax
Reform Act of 1969 (hereinafter sometimes referred to as the TRA
'69 Blue…
IRCProposed Rules (FR)Proposed Oct 31, 2023
…tinues to read as follows:
Authority:
80 Stat. 379; sec. 3, 60 Stat. 238, as amended; 5 U.S.C. 201, 552.
2. Add subpart A before § 323.1;
3. Revise the first sentence of § 323.1; and
4. Add subpart B after § 323.5.
The additions and revision read as follows:
PART 323—DISCLOSURE OF RECORDS
Authority:
80 Stat. 379; sec. …
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
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…
IRCFinal Rules (FR)Nov 12, 2020
…nd the health benefit plan.
Back to Citation
86.
18 U.S.C. 1836(b).
Back to Citation
87.
5 U.S.C. 552.
Back to Citation
88.
18 U.S.C. 1839(5)-(6).
Back to Citation
89.
5 U.S.C. 552.
Back to Citation
90.
5 U.S.C. 552(b)(4).
Back to Citation
91.
42 U.S.C. 1320b-23(c).
Back to Citation
92.
42 U.S.C. 300gg(18)(e).
B…
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 RulingsJan 4, 2011★ strong match
discretion. Under this a
standard, petitioner must persuade the Court that respondent's
determination was unreasonable, arbitrary, or capricious. See Buzzetta Constr. Corp. v. Commissioner, 92 T.C. 641, 648 (1989) .
Petitioner has failed.to do so.
Section 401(a) lists requirements which must be met in order
for a.trus…
IRCRegulationsMay 18, 2016
…nd has covered compensation of $32,000. Employee M's accrued benefit as of December 31, 1995, is $4,552, the greater of—(1) $4,552, the sum of Employee M's accrued benefit frozen as of December 31, 1994, ($4,200) and the amended formula applied to Employee M's years of service after 1994 ((0.75 percent × $32,000 × 1 ye…
IRCCourt RulingsJan 30, 2007
…idered in default. The loan was
repaid in 2000 by an offsetting distribution from Plan 15105 of
$15,552. During October or November of 2000, petitioner made a
direct rollover of $286,390 from Plan 15105 into his Fidelity
Investments IRA Rollover Account (Fidelity IRA). Fidelity
IRCCourt RulingsSep 24, 2007
…s order (QDRO) is
includable in petitioner's 2002 taxable income ;
(2) whether $8,119 .20 of the $9,552 in Social Security
benefits received by petitioner in 2002 is includable in
petitioner's 2002 taxable income ;
(3) whether petitioner is liable for additions to tax under
section 6651(a)(1)2 and (2) in the amounts of…
IRCCourt RulingsFeb 9, 2023
…ncrete & Supply, LLC ,
566 U.S. 478, 483 (2012) (citing John R. Sand & Gravel Co. v. United
States, 552 U.S. 130, 139 (2008)). “ [ S ] tare decisis in respect to statutory
interpretation has ‘special force,’ for ‘Congress remains free to alter
what we have done.’” John R. Sand & Gravel Co. , 552 U.S. at 139
(quoting Pa…