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…
77 FR 70620 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans IRCProposed Rules (FR)Proposed Nov 26, 2012
….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996). Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010).
2. In § 146.121, paragraph (f) is revised t…
IRCCourt RulingsAug 13, 1990★ strong match
hould prevail on the substantive issues as a matter of law. Rule 121(b); Naftel v. Commissioner, supra at 529; Espinoza v. Commissioner, supra at 416. Rule 121(d) provides that “an adverse party may not rest upon the mere allegations or denials of such party’s pleading, but such party’s response, by affidavits or as ot…
IRCRegulationsDec 30, 2016
…se of F's claims experience. (ii) Conclusion. See Example 1 in 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) for a conclusion that the issuer does not violate the provisions of 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) similar to the provisions of this paragraph (c)(2) because the issuer blends the rate so that t…
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008★ strong match
are petitioner's and
respondent's cross-motions for summary ·judgment pursuant to Rule
121.
Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years in 1ssue.
Rule 121(a) provides that either…
IRCCourt RulingsSep 28, 2011★ strong match
…
there is no genuine issue of materïal fact and a decision may be
rendered as a matter of law. Rule 121(a) and (b); Fla. Peach
Corp. v. Commissioner, 90 T.C. 678, 681 (1988). The moving party
bears the burden of proving that there is.no genuine issue of
material fact, and factual inferences are.viewed in a light most
f…
IRCCourt RulingsMay 25, 2005★ strong match
…
judgment motion, and the sole argument presented in the response
to the second motion is that Rule 121 does not provide for
- 8 -
repeated motions for summary judgment. This argument is without
merit. Rule 121 does not prevent successive motions for summary
judgment.
We conclude that petitioners are liable for the 10-…
IRCCourt RulingsDec 11, 2003
121 T.C. No. 19
UNITED STATES TAX COURT
FORTUNATO J. MENDES, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16032-95. Filed December 11, 2003.
P has been continuously incarcerated since June 17,
1988. For P’s 1988 taxable year, R (1) determined a tax
deficiency based upon amounts reported on inf…
78 FR 33158 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans IRCFinal Rules (FR)Jun 3, 2013
….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996).
Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010).
8. In § 146.121, paragraph (f) is revised t…
IRCCourt RulingsNov 1, 2007★ strong match
…e is no genuine issue of any material fact and
a decision may be rendered as a matter of law . Rule 121(a) and
(b) ; see Sundstrand Corp . v . Commissioner , 98 T .C . 518, 520
(1992), affd . 17 F .3d 965 (7th Cir . 1994) .
The moving party bears the burden of proving that there is
no genuine issue of material fact, an…
IRCCourt RulingsAug 6, 1991related by meaning
itle (other than this subsection) applies with respect to such amount. The pertinent portion of sec. 1.72-2(a)(3)(i), Income Tax Regs., is as follows: Sections 402 and 403 provide that certain distributions by employees’ trusts and certain payments under employee plans are taxable under section 72. * * * For purposes o…
IRCCourt RulingsOct 1, 2025★ strong match
is entitled
to judgment as a matter of law . See Rule 121(a)(2); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant summary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party. Sundstrand Corp. , 98 T.C.
at 520. The nonmoving party may …
IRCCourt RulingsJan 3, 2011★ strong match
…ion for summary judgment anc respondent's cross-motion for
- 3 -
summary judgment spursuant to Rule 121. Respondent determined a
deficiency of $33,057 in petitioner's Federal rincome tax for tax
IRCCourt RulingsJan 17, 2024related by meaning
ies.
Subchapter C, consisting solely of section 6751, sets forth “Procedural
Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides
evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
for the 5-percent excise
tax on prohibited transactions under section 4975(a) for 1982 to
1993.
2. Whether petitioners are liable for additions to tax under section 6651(a)(1) for 1982 to 1993. We hold that they are
to the extent discussed below.
At trial, respondent conceded that petitioners are not
liable for the 100…
IRCCourt RulingsDec 4, 2017
…onal alimony" is a class of alimony that a Tennessee court may
award. See Tenn. Code Ann. sec. 36-5-121(d)(1) through (g)(1). It terminates on
the death of he recipient. Id. sec. 36-5-121(g)(3). It is described as a sum of
money payable by a spouse for a determinate period and awarded "when the court
finds that rehabil…
110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
(1) 90-DAY PERIOD.--* * * an action for
declaratory judgment under this part must be commenced
within 90 days after the date on which the Secretary or his delegate sends by certified or registered mail his
determination with respect to the qualification of the
plan to the person requesting such determination.
[H.R. 2, …
IRCCourt RulingsAug 31, 2021
…ay move for summary judgment regarding all or any part of the legal issues in controversy. See Rule 121(a); Wachter v. Commissioner, 142 T.C.
140, 145 (2014). We may grant summary judgment if the pleadings, stipul ations
and exhibits, and any other acceptable materials show that there is no genuine
dispute as to any ma…
IRCCourt RulingsJul 5, 1983related by meaning
the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
ment 2009-88 Announcement 2009-88
A list is provided of organizations now classified as private foundations.
Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…