91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…lection authorities to collect any such debts,[198] including netting in accordance with 45 CFR 156.1215, as applicable, as part of HHS' integrated monthly payment and collections cycle. Additionally, since the Departments are not finalizing the proposed direct Departmental collection of the administrative fee and to e…
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023
…82. HHS intends to propose in notice and comment rulemaking in the near future to amend 45 CFR 156.1215 to provide that administrative fees for utilizing the No Surprises Act Federal IDR process for health insurance issuers that participate in financial programs under the ACA would be subject to netting as part of HHS…
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…
IRCCourt RulingsOct 19, 2010related by meaning
ollars, petitioner's
persistence in pursuing a tax protest agenda is inexcusable'" and
"A penalty in the maximum amount of $25,000 is appropriate when lesser amounts have not deterred a taxpayer's defiance of the tax
laws and of the rulings of the courts." Id. (quoting January 11,
2008, order and order to show cause).
…
IRCCourt RulingsFeb 9, 2023related by meaning
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…
T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b… IRCTreasury DecisionsDec 7, 2015related by meaning
istrator Centers for Medicare & Medicaid Services Approved: October 22, 2015
Sylvia M. Burwell, Secretary Department of Health and Human Services Note (Filed by the Office of the Federal Register on July 13, 2015, 8:45 a.m., and published in the issue of the Federal Register for July 14, 2015, 80 F.R. 40661)
DEPARTMENT…
82 FR 47656 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act; Proposed Rulemaking IRCProposed Rules (FR)Proposed Oct 13, 2017related by meaning
CTION:
Notice of proposed rulemaking by cross-reference to temporary regulations.
( printed page 47657)
SUMMARY:
In this issue of the
Federal Register , the Department of Treasury and the IRS are issuing two sets of temporary regulations related to section 9815 of the Internal Revenue Code. The first set of temporary r…
IRCCourt RulingsMay 25, 2005related by meaning
ibution was not from an IRA, it would not qualify for the
exception for higher education expenses, even if it were used for
higher education expenses. Petitioners stated in their petition that the distribution
was from a section 401(k) account, a fact which petitioners have
not denied. Petitioners did not respond to th…
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 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 RulingsJul 31, 2000
…974).
Commissioner
, supra
at 443; see also Loftin & Woodard, Inc. v.
United States
, supra
at 1214-1215; Crosby v. United States
, supra
at 1388; Magnon v. Commissioner
, 73 T.C. 980, 993-994 (1980).
Petitioners argue that the excess contributions were paid to
the employee/owners as compensation for their services. We…
IRCCourt RulingsMar 20, 1997
…tates
, 621 F.2d 731, 735
(5th Cir. 1980); Loftin & Woodard, Inc. v. United States
, 577
F.2d 1206, 1215 (5th Cir. 1978); Noble v. Commissioner
, supra
at
443; Magnon v. Commissioner
, supra
at 993-994. When a
corporation confers an economic benefit upon a shareholder in his
capacity as such, without an expectation of …
T.C. Memo. 1998-64 — Reed Smith Shaw & McClay; William J. Smith, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 17, 1998
… term "possession" means "physical"
possession of the security. Wagner v. Hart Chem. Co.
,
supra
at 1215.
In this case, the tax matters partner has not shown
that delivery of the Saztec stock was made to the trust
under section 8313(a) of the Pennsylvania Commercial Code
between April 7, 1987, when the contribution agr…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
IRCCourt RulingsApr 12, 1979
…n greater than that allowed by the terms of the plan. Irwin B. Schwabe Co. v. Commissioner, 17 T.C. 1215 (1952). Therefore, we hold that the respondent properly excluded the compensation paid to individuals employed by petitioner for less than 5 months in computing the limitation on deduction for contributions to the p…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018related by meaning
.S.C. 14406 (protecting organizations and health providers from being required to inform or counsel persons pertaining to assisted suicide); 42 U.S.C. 18023 (blocking any requirement that issuers or exchanges must cover abortion); 42 U.S.C. 18113 (protecting health plans or health providers from being required to provi…
IRCCourt RulingsNov 6, 1962
…h pensions, profit-sharing plans, and annuities, this Court stated in Irwin B. Schwabe Co., 17 T.C. 1215, 1220, referring specifically to section 23(p)(l)(A), I.K..C. 1939, that—
In the applicable revenue laws the loss of such benefits (under pension plan] is commonly referred to as a forfeiture of employees’ benefits.…
82 FR 47658 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act; Proposed Rulemaking IRCProposed Rules (FR)Proposed Oct 13, 2017related by meaning
ice (IRS), Treasury.
ACTION:
Notice of proposed rulemaking by cross-reference to temporary regulations.
SUMMARY:
In this issue of the
Federal Register , the Department of Treasury and the IRS are issuing two sets of temporary regulations related to section 9815 of the Internal Revenue Code. The first set of temporary r…
IRCCourt RulingsMar 5, 2018related by meaning
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…