82 FR 47656 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act; Proposed Rulemaking IRCProposed Rules (FR)Proposed Oct 13, 2017related by meaning
… Handbook
for more details.
Department of the Treasury
Internal Revenue Service
26 CFR Part 54
[REG-129631-17]
RIN 1545-BN91
AGENCY:
Internal Revenue Service (IRS), Treasury.
ACTION:
Notice of proposed rulemaking by cross-reference to temporary regulations.
( printed page 47657)
SUMMARY:
In this issue of the
Federal Re…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026★ strong match
…nacting new provisions using many of the same Code section numbers as TEFRA. BBA § 1101(a), (c)(1), 129 Stat. at 625 – 37. The BBA
generally governs partnership audit and adjustment procedures for
22
partnership returns filed for partnership years beginning after
December 31, 2017. BBA § 1101(g) , 129 Stat. at 638.
Und…
IRCRegulationsSep 9, 2016
(d)(6)(ii) (ii) Sections 410(b), 401(a)(26), and 129(d)(8). For purposes of paragraph (c) of this section, relating to the separate application of sections 410(b), 401(a)(26), and 129(d)(8) to the employees of a qualified separate line of business, the determination whether an employer operates qualified separate lines…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…6
9,149
0
0
Clerical workers prepare and distribute comparative analyses upon participant request
2,129,516
0.083
177,460
65.99
11,710,585
2.79
2,477,543
Clerical workers maintain recordkeeping
2,129,516
0.083
177,460
65.99
11,710,585
0
0
Total
2,129,536
355,020
23,433,073
2,477,543
1.5. Overall Summary
IRCCourt RulingsJan 17, 2024related by meaning
9 73) is
contained within Subtitle D, Chapter 43. Section 4975 imposes “a tax”
on any prohibited transaction engaged in by any disqualified person of a tax-exempt p lan or entity ( including an IRA ) . See § 4975(a). The initial tax currently imposed is 15% of the amount involved in the prohibited transaction, rising …
IRCCourt RulingsJun 6, 2016related by meaning
igher than not frivolous. R sec. 1.6662-4(e)(2)(i). A return
position that is merely arguable does not satisfy the reasonable basis standard. Id.
-16- [*16] sec. 1.6662-3(b)(3). A position generally has a reasonable basis if the
position is reasonably based on one or more authorities listed in section 1.66624(d)(3)(iii…
89 FR 54284 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCFinal Rules (FR)Jun 28, 2024related by meaning
olding period raises serious concerns that the family pass-through entity exception is being used inappropriately to circumvent the Disallowance Rule. The Treasury Department and the IRS disagree that the Treasury Department and the IRS lack authority to promulgate an anti-abuse rule. Section 170(h)(7)(G) is a specific…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
—Shared Responsibility for Employers Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b). (136) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discha…
IRCCourt RulingsJul 31, 2000
…unt of $164,406. At the time of conversion, the Cgroup term policy’s conversion credit balance was $129,411.70,
and $122,941.12 of that amount ($129,411.70 x 95%) was
- 57 -
transferred to the C-group conversion UL policy for potential
Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona… IRCNoticesModified Dec 22, 2008
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
IRCCourt RulingsDec 22, 2008related by meaning
foregoing quoted terms are specially defined and used
under the "Public Salary Tax Act of 1939" ;
3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor
"taxpayer," nor "non-resident alien," nor any other
"legal entity" "made liable for" or "subject to" any
"internal reve…
Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4… IRCNoticesObsolete Dec 26, 2007
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
IRCCourt RulingsMar 28, 2012related by meaning
ctive for determinations made after October 16, 2006, this Court has
jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v.
Commissioner, 130 T.C. 44, 48 & n.4 (2008).
- 6 -
Respondent does not dispute that petit…
Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr… IRCAnnouncementsMay 9, 2005
…ALTH PLANS
Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
IRCCourt RulingsMay 19, 2011related by meaning
ion 6662(a) and (b) (2).
Generally, section 6662(a) and (b) (1) authorizes the
Commissioner to impose a 20-percent penalty on the portion of an
- 72 - underpayment of income tax attributable to negligence or
disregard of rules or regulations. The term "negligence"
includes any failure to make.a reasonable attempt to co…
IRCCourt RulingsDec 8, 1987related by meaning
tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
IRCCourt RulingsJun 29, 2015
…ed into a series of
agreements. Pursuant to these agreements the Summa subsidiaries paid JC Export
$129,791, $672,048, $625,438, and $810,646 on January 18, April 23, July 25,
- 7 -
[*7] and December 22, 2008, respectively.5 Summa also paid $1,083 of expenses
on behalf of JC Export and JC Holding during 2008. The Summa…
81 FR 27011 — Additional Limitation on Suspension of Benefits Applicable to Certain Pension Plans Under the Multiemployer Pension Reform Act of 2014 IRCFinal Rules (FR)May 5, 2016related by meaning
uty Commissioner for Services and Enforcement.
Approved: April 29, 2016.
Mark J. Mazur,
Assistant Secretary of the Treasury (Tax Policy).
Footnotes
1. Section 201 of MPRA makes parallel amendments to section 305 of the Employee Retirement Income Security Act of 1974, Public Law 93-406 (88 Stat. 829 (1974)), as amended…
IRCCourt RulingsJun 14, 2012related by meaning
ed work in her capacity as Yolo's employee or officer. Consistent with
our conclusion above, we sustain respondent's disallowance of these deductiòns. IV. Additions to Tax and Penalties
A. s Burden of Proof
Respondent bears the burden of production with regard to the section
6651(a)(1) and (2) additions to tax and the …
IRCCourt RulingsApr 2, 2020
…ng given a reasonable
opportunity to present such evidence. Id.; see also Giamelli v. Commissioner, 129
T.C. 107, 114-115 (2007).
- 17 -
[*17] In evaluating a determination by the Office of Appeals after a CDP hearing,
the Court's general standard of review for evaluating challenges to the underlying
tax liability is d…