84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…ased Medicare eligibility or entitlement.[169]
Large group health plans, as defined by Code section 5000(b)(2) without regard to Code section 5000(d) (that is, plans of employers that employ at least 100 employees), that cover Medicare beneficiaries who are under age 65, entitled to Medicare on the basis of disability,…
IRCCourt RulingsSep 27, 1990related by meaning
. United States, 872 F.2d 564, 568-570 (3d Cir. 1989).
Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
IRCCourt RulingsJun 23, 2025related by meaning
one fluent in English knows that the word ‘includes’ cannot be assumed
to mean ‘includes only .’ . . .”) ; Waltne r , 107 T.C.M. (CCH) at 1201 (citing United States v. Lat ham , 754 F.2d 747, 750 (7th Cir. 1985) ) .
In sum, petitioner’s arguments have been rejected by the courts
in hundreds of cases, and we will not di…
75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Jun 16, 2010related by meaning
URE AND ADMINISTRATION
Paragraph 1.
The authority citation for part 301 continues to read in part as follows:
Authority:
26 U.S.C. 7805 * * *.
Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows:
§ 301.6404-0
Table of Contents.
* * * * *
§ 301.6404-4 Suspension of interest and c…
IRCCourt RulingsJan 17, 2024related by meaning
United States Tax Court
T.C. Memo. 2024-6
CLAIR R. COUTURIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed January 17, 2024.
—————
Michael Eddison Romero , Alvah Lavar Taylor, Daniel W. Soto , and
Jonathan T. Amitrano , for petitioner.
Hilary E. March , Laura A. Pr…
IRCCourt RulingsAug 10, 2000related by meaning
6, 682 (1977); Pawlak v.
Commissioner
, T.C. Memo. 1995-7. Finally, there is no indication
- 8 -
2
Petitioner contends that under IRS Publication 560, Retirement Plans for the Self-Employed, contributions can be
retroactively applied to the previous year if the contributions
are made by the due date of the employer’s r…
IRCCourt RulingsFeb 25, 2016related by meaning
4. Respondent has allowed exactly those amounts as deductions for 2004
and 2005. Petitioner has made no attempts to provide the Court with evidence of any other payments for travel and meals and entertainment expenses. With the
heightened substantiation requirements under section 274 and the lack of
additional document…
PLR 200750002 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsDec 14, 2007
…t balance if the
amount is not in excess of the dollar limit provided in section 411(a)(11) (i.e., $5000.00
adjusted for inflation) if certain conditions are met.
The Plan provides for acceptance of transfers of a participant's account balance
from another eligible deferred compensation plan as provided for in section …
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
tion or Section 4947(a)(1) Trust Treated as Private Foundation, if the organization is required to file at least 250 returns during the calendar year. Section 6011(e)(4) was added to the Code in 2010 by section 522, Title V, of the Hiring Incentives to Restore Employment (HIRE) Act, Public Law 111-147, 124 Stat. 71, to…
IRCCourt RulingsMar 9, 2011related by meaning
ds of thousands of dollars
in DISC commissions each year from a well-established business,
and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount.
-28IV. Section 6662(a) Penalty
Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
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 …
IRCFinal Rules (FR)Sep 16, 2025related by meaning
dent of Documents, U.S. Government Publishing Office, Washington, DC 20402, or by visiting the IRS website at
http://www.irs.gov.
Drafting Information The principal authors of these regulations are Kara M. Soderstrom, Christina M. Cerasale, and Jessica S. Weinberger of the Office of the Associate Chief Counsel (Employe…
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 …
77 FR 76426 — Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated IRCProposed Rules (FR)Proposed Dec 28, 2012related by meaning
velopment.
List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
Partial Withdrawal of Notice of Proposed Rulemaking Accordingly, under the authority of 26 U.S.C. 7805, §§ 1.509(a)-4(i)(5)(ii)(B) and 1.509(a)-4(i)(8) of the notice of proposed rulemaking (REG-155929-06) that was publish…
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 …
PLR 201822004 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJun 1, 2018
… to rollover contributions is not in excess
of the dollar limit under section 411(a)(11)(A) (i.e., $5000 adjusted for inflation), no
amount has been deferred under the plan by or for the participant during the two-year
period ending on the date o f the distribution, and there has been no prior distribution
under the pl…
IRCCourt RulingsSep 15, 2005related by meaning
Court, the two cases were
consolidated for hearing on the motions to dismiss. The hearing
was held on November 29, 2004, in San Francisco, California. Discussion
Section 6033(a)(1) requires an organization exempt from
taxation under section 501(a) to file."an annual return, stating
specifically the ite s of gross incom…
PLR 201731009 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsAug 4, 2017
… to
rollover contributions is not in excess of the dollar limit under section 411(a)(11)(A) (i.e.,
$5000 adjusted for inflation), no amount has been deferred under the plan by or for the
participant during the two-year period ending on the date of the distribution, and there
has been no prior distribution under the pla…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
o calculate current liability and to determine the required contribution are set forth.
EXEMPT ORGANIZATIONS
Announcement 2006-55 Announcement 2006-55 Aviation Safety Council, Inc., of Pasadena, CA; Budget and Credit Counseling Services, Inc., of New York, NY; and Mason Credit Counseling, Inc., of Hauppauge, NY, no lon…