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 RulingsFeb 22, 1989related by meaning
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
IRCCourt RulingsAug 1, 2012★ strong match
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
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[…
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 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 RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsSep 24, 2007★ strong match
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…
IRCCourt RulingsMar 9, 2011★ strong match
ities. Classification of the
transaction as a prohibited transaction under section
408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is
subject to a 10-percent additional tax. See secs. 72(t),
408(e) (2) (]B). In cases where the Service att…
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 RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
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 RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
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10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
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…
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011related by meaning
Form 886-A,Explanation of Items);
Form 870,
Waiver of Restriction on Assessments and Collection of Deficiency in Tax and Acceptance of Overassessment; notices of proposed deficiency that allow the taxpayer an opportunity for review in the Office of Appeals (30-day letters); notices pursuant to section 6213(b) (mathemat…
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 RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
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 RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…