IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
IRCCourt RulingsJun 17, 1997★ strong match
he penalties in
docket Nos. 2545-94 and 9230-94; an
appropriate decision for respondent
will be entered in docket No.
5754-94 as to the deficiency and the addition to tax under section
6651(a)(1) and for petitioner with
respect to the penalty
.
85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency IRCFinal Rules (FR)Nov 6, 2020
at least the ten essential health benefits described in section 1302(b) of the PPACA and must comply with the Exchange's cost-sharing protections,[14] which includes providing all ACIP recommended vaccines without cost sharing. See sections 1331(a)(1), (a)(2)(B) and (b)(2) of PPACA, and 42 CFR 600.405(a) and 600.510(b)…
IRCCourt RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
IRCRegulationsJul 12, 2016
…20% of $500,000 + 15% of $400,000=) 160,000 264,000 40,000 50,000 Totals: 2,400,000 435,000 670,750 108,750 115,000 (2) Organization Y, whose taxable year is the calendar year, was first treated as an organization described in section 501(c)(3) on February 1, 1977. Y made the expenditure test election under section 501…
IRCCourt RulingsJul 31, 2000related by meaning
red all of petitioners’
arguments for contrary holdings; those arguments not discussed
herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent
necessary to reject or sustain each determination . We also have
considered all of respondent’s arguments a…
IRCCourt RulingsOct 8, 2003related by meaning
the service provider, the
former did not pay the latter for its services within 2-1/2
months after the close of the respective calendar years in which the services were performed.
4
Nor have petitioners made the
requisite showing to rebut the presumption that Clarkston’s
arrangement with J.D. as to its services did not…
79 FR 8544 — Shared Responsibility for Employers Regarding Health Coverage IRCFinal Rules (FR)Feb 12, 2014
…lency The proposed regulations provide that, for purposes of determining full-time employee status, 130 hours of service in a calendar month is treated as the monthly equivalent of at least 30 hours of service per week, provided that the employer applies this equivalency rule on a reasonable and consistent basis. This …
81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCProposed Rules (FR)Proposed Jun 1, 2016
…ponse:
Reporting Burden:
§ __.110(a)—0.25 hours.
§ __.110(b)—0.50 hours.
Recordkeeping Burden:
§ __.108(b)—20 hours.
§ __.110(b)—100 hours.
Disclosure Burden (Board only):
§§ __.130 and __.131—24 hours.
OCC
Number of Respondents:
17 (17 for reporting requirements and § __.40(b) and § __.110(b) recordkeeping requirement…
IRCFinal Rules (FR)Dec 30, 2024
…mber 27, 1988, the Department of the Treasury (Treasury Department) and the IRS published Notice 88-130, 1988-2 CB 543, which provides rules for determining when a tax-exempt bond is retired for purposes of sections 103 and 141 through 150. Notice 88-130 provides in part that a tax-exempt bond is retired when there is …
IRCCourt RulingsFeb 28, 2024related by meaning
8
years on June 10, 2016. That notice was issued timely because, as of
3
The opposite presumption may apply for certain statutes affect ing procedural rights. See Chenault , 37 F.3d at 53 8. Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 8…
IRCCourt RulingsApr 2, 2018
…d under section 409A is irrelevant. Section 409A addresses the
¹°See e.g., Jackson v. Commissioner, 108 T.C. 130.
"Jackson v. Commissioner, 108 T.C. at 132.
¹²Jackson v. Commissioner, 108 T.C. at 138.
¹³See also Gump v. United States, 86 F.3d 1126, 1128-1129 (Fed. Cir.
1996); Milligan v. Commissioner, 38 F.3d at 1099.
…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…criptions x $181.15 total average patient out-of-pocket and insurer expenditure per prescription = $108,831,984,000. This represents 16.3 percent of $667,000,000,000 total annual prescription expenditures. (
Source: 2022 Medical Expenditure Panel Survey,
Agency for Healthcare Research and Quality, Department of Health …
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
IRCCourt RulingsDec 2, 2013
…solvent at the time, no part of the distribution is includible in gross
income by virtue of section 108(a)(1)(B).7
Respondent argues that petitioners failed to prove that they were insolvent.
But more fundamentally, respondent argues that because the surrender of the life
insurance policy resulted in the full satisfact…
IRCCourt RulingsJul 11, 2012related by meaning
ditional tax provided by section 72(t)), penalties, and statutory
interest.. See Katz v. Commissioner, 115 T.C. 329, 338-339 (2000). The record
. 12 - does not establish that petitioners received a.notice of deficiency for 2007 and
consequently a challenge to petitioners' 2007 tax liability is allowed in thi
judicial p…