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…
79 FR 10296 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCFinal Rules (FR)Feb 24, 2014
… under the plan.
* * * * *
Waiting period has the meaning given the term in 45 CFR 147.116(b).
PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET
25. The authority citation for part 146 continues to read as follows:
Authority:
Secs. 2702 through 2705, 2711 through 2723, 2791, and 2792 of the PHS Act (42 U.S.C.…
Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20… IRCRevenue ProceduresJan 2, 2019
… STATUS?
185
.01 Scope
185
.02 Employer must request the determination under § 414(n)
185
.03 Forms
186
.04 Employer is responsible for determining continuing status under § 414(n)
186
.05 Pre-approved plans
186
.06 Required information for § 414(n) determination
186
SECTION 18. WHAT ARE THE PROCEDURES FOR REQUESTING S…
81 FR 75316 — Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance IRCFinal Rules (FR)Oct 31, 2016
e, those working overseas as an expatriate or military personnel being deployed.
* * * * *
PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET 13. The authority citation for part 146 continues to read as follows:
Authority:
Secs. 2702 through 2705, 2711 through 2723, 2791, and 2792 of the Public Health Service …
IRCCourt RulingsFeb 28, 2024related by meaning
” —not ours. See United
44
States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
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
…ther limits are not imposed on a yearly basis, the policy year is the calendar year.
* * * * *
PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET
3. Section 146.101 is amended by—
A. Revising the first sentence of paragraph (a).
B. Revising paragraph (b)(4).
The revisions read as follows:
§ 146.101
Basis and S…
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
78 FR 33158 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans IRCFinal Rules (FR)Jun 3, 2013
…the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR Parts 146 and 147 as follows:
PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET
7. The authority citation for part 146 continues to read as follows:
Authority:
Secs. 2702 through 2705, 2711 through 2723, 2791, and 27…
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 $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsOct 28, 1965related by meaning
… certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually paid by him to Ada and (b)…
IRCCourt RulingsJul 18, 1968related by meaning
62 (or sec. 404) and under other provisions, such as interest tolvich is specifically allowable as a deduction under section 16$. [Emphasis supplied.] H. Rept. No. 749, 88th Cong., 1st Sess. p. 82 (1968). See also H. Rept. No. 749, p. A92 (1963).
In view of these statutory changes, McNutt-Boyce Co., supra, is no longer…
IRCCourt RulingsJan 30, 2007
… adjusted gross
income."
- 30 -
A yearend account statement shows that petitioners paid a total
of $186,370 in interest on margin loans during 2000. The $19,255
appears to be a portion of the $186,370, which respondent already
conceded petitioners were entitled to deduct. The record
establishes that petitioners paid on…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsFeb 25, 1959related by meaning
y at the time it was terminated and hence section 165 (b) did not apply. Eespondent has cited no case which would require a different conclusion here. On the facts here involved it is our opinion that the distribution received by petitioner in the year 1955 was paid to him on account of his separation from the service …
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-… IRCFinal Rules (FR)Nov 13, 2013
adopts as final the interim final rule with comment period amending 45 CFR part 146, which was published on February 2, 2010, in the
Federal Register at 75 FR 5410, with the following changes, and further amends part 147 as set forth below:
PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET
1. The authority c…
IRCCourt RulingsMar 31, 1961related by meaning
by the total of its liabilities at such time * * *
The contention of the petitioners is incorrect; the respondent’s position is clearly the right one. The Excess Profits Tax Act of 1950 was enacted by the Congress on January 2, 1951, and became law upon signature by the President on the morning of January 3, 1951, at 1…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …