89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR parts 144, 146, and 148 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
9. The authority citation for part 144 continues to read as follows:
Authority:
42 U.S.C. 300gg through 300gg-63, 300gg-91…
IRCCourt RulingsFeb 6, 1992related by meaning
Parker, Judge:
By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:
_Additions to tax_
Sec. Sec. Sec.
TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1/31/86 $64,117 $3,206.85 50 percent $16,029.25
of the interest …
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR parts 144, 146, 147, and 155 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
16. The authority for part 144 is revised to read as follows:
Authority:
42 U.S.C. 300gg through 300gg-63, 300gg-91, …
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was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…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 RulingsJun 11, 1996related by meaning
g, we give effect to the
plain meaning of the words used therein and sustain respondent's
determination that petitioners are liable for the 10-percent additional tax under section 72(t).
We have considered petitioners' remaining arguments and find
them unpersuasive.
3. Conclusion
In order to give effect to our disposit…
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
IRCFinal Rules (FR)Aug 3, 2018
…the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR parts 144, 146, and 148 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
7. The authority citation for part 144 continues to read as follows:
Authority:
42 U.S.C. 300gg through 300gg-63, 300gg-91…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1996-450
UNITED STATES TAX COURT
THEODORE SOURIS, P.C., A DISSOLVED CORPORATION,
AND THEODORE SOURIS, AS SUCCESSOR IN INTEREST
OF THEODORE SOURIS, P.C., Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 639-95. F…
81 FR 75316 — Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance IRCFinal Rules (FR)Oct 31, 2016
…the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR parts 144, 146, 147, and 148 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
11. The authority citation for part 144 continues to read as follows:
Authority:
Secs. 2701 through 2763, 2791, and 2…
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…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…nces.
(2) The provisions in this section are intended to be severable from the provisions in §§ 149.140, 149.510, and 149.530, from any grant of forbearance from removal resulting from this subpart, and from any provision referenced in §§ 149.140, 149.510, and 149.530.
18. Section 149.140 is amended by:
a. Revising par…
81 FR 38020 — Expatriate Health Plans, Expatriate Health Plan Issuers, and Qualified Expatriates; Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Dura… IRCProposed Rules (FR)Proposed Jun 10, 2016
… stated in the preamble, the Department of Health and Human Services proposes to amend 45 CFR parts 144, 146, 147, 148, and 158 as set forth below:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
24. The authority citation for part 144 continues to read as follows:
Authority:
Secs. 2701 through 2763, 2791, …
IRCCourt RulingsSep 25, 2019related by meaning
w that there is a
genuine dispute for trial that he had reasonable cause for not paying the unpaid tax
on the 2013 return made for him by RA Landadio. C. Summary Judgment
Rule 121(b) provides that, in the absence of a genuine dispute as to any
material fact, and if a decision may be rendered as a matter of law, we must…
75 FR 27122 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Dependent Coverage of Children to Age 26 Under the Patient Protection and A… IRCFinal Rules (FR)May 13, 2010
A, Subchapter B as follows:
PART 144—REQUIREMENTS RELATING TO HEALTH INSURANCE COVERAGE
Subpart A—General Provisions
1. Section 144.101 is amended by- A. Revising paragraph (a).
B. Redesignating paragraphs (b), (c) and (d) as paragraphs (c), (d) and (e), respectively.
C. Adding a new paragraph (b).
D. Revising the firs…
IRCCourt RulingsAug 28, 1996related by meaning
xable year. The prior notice,
mailed on February 6, 1995 (February notice), contained a
determination of an income tax deficiency and accuracy-related penalty under section 6662 for petitioner's 1991 tax year.
Petitioner questioned the validity of the August notice in his
petition filed in this case. The excise tax and…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
REG-106796-12 — These proposed regulations provide guidance on the application of section 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for serv… IRCProposed Rules (FR)Proposed May 28, 2013
…ear to which any portion of the payment could be attributed is F’s 2019 taxable year. Accordingly, $140,000 of the $200,000 payment is attributed to services performed by O in L’s 2019 taxable year.
(vi) The portion of the deferred deduction remuneration attributed to a disqualified taxable year under paragraph (d) of …
IRCCourt RulingsFeb 21, 2012related by meaning
Respondent prepared decisiori.documents reflecting respolident's
concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and .
sanctions against respondent based on "reckless professional behavior."
Petitioner is frustr…
IRCCourt RulingsOct 3, 1995related by meaning
income tax return. Although
the Court can appreciate petitioners' frustration, we must
nevertheless note that matters involving interest do not, as a general rule, fall within the scope of this Court's jurisdiction.
Perkins v. Commissioner
, 92 T.C. 749, 752 (1989); LTV Corp. v.
Commissioner
, 64 T.C. 589, 597 (1975); …