T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
is obtained on or before the date the IRS issues a notice of
deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74
…
IRCCourt RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…
81 FR 19086 — Amendments to the Definition of Broker or Dealer in Securities IRCProposed Rules (FR)Proposed Apr 4, 2016related by meaning
regulations at 31 CFR Chapter X.
See 31 CFR 1010.100(e).
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2.
31 U.S.C. 5311.
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3.
31 U.S.C. 5318.
Back to Citation
4. Treasury Order 180-01 (Jul. 1, 2014).
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5.
31 U.S.C. 5318(g) was added to the BSA by section 1517 of the Annunzio-Wylie Act; it was expanded by section …
IRCRegulationsJun 17, 2024
Sections 54.9801-1 through 54.9801-6, and 54.9831-1 and this section are applicable for plan years beginning on or after July 1, 2005. Notwithstanding the previous sentence, for short-term, limited-duration insurance sold or issued on or after September 1, 2024, the definition of short-term, limited-duration insurance …
IRCCourt RulingsNov 17, 2016related by meaning
tion 6011(a) requires that any person made liable for a tax or with
respect to its collection "shall make a return or statement according to the forms and regulations prescribed by the [Treasury] Secretary." "The return or statement
shall include therein the information required by the applicable regulations or
forms."…
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011related by meaning
use these regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Code, the notice of proposed rulemaking preceding these regulations was submitted to the Chief Counsel for Advocacy of the Small Busin…
83 FR 54420 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCProposed Rules (FR)Proposed Oct 29, 2018
the Departments have jurisdiction over those provisions.
See
section 9801(f) of the Code, section 701(f) of ERISA, and section 2704(f) of the PHS Act; see also26 CFR 54.9801-6, 29 CFR 2590.701-6, 45 CFR 146.117, and 45 CFR 147.104(b)(3)-(5). The proposed rules do not affect the group health plan special enrollment peri…
PBGCProposed Rules (FR)Proposed Jul 22, 2010related by meaning
debtor's employing agency or to the Financial Management Service to implement salary offset, unless the employee files a timely request for a hearing; (v) That a final decision on the hearing, if requested, will be issued at the earliest practicable date, but not later than 60 days after the filing of the request for a…
IRCCourt RulingsDec 2, 2013related by meaning
or disbarment of any practitioner". 31
C.F.R. sec. 10.4(a)(2007).
- 6 -
or the Form 1099-R issued by Guardian.5 After preparing the return, Mr. Neuman reviewed it with petitioners, who then timely filed it.
In March 2012 respondent issued to petitioners a notice of deficiency for
2010, determining a deficiency of $6,94…
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…
Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022 IRCNoticesModified Jan 8, 2024
…dual retirement annuity described in section 408(b).
6 The definition of “State” for purposes of 42 USC 1395x(r)(1) is in 42 USC 410(h), which provides that the term “State” includes the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa.
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
IRCRegulationsSep 13, 2021
…ect. Significant break in coverage means a significant break in coverage within the meaning of § 54.9801-4(b)(2)(iii). Special enrollment means enrollment in a group health plan under the rights described in § 54.9801-6 or in group health insurance coverage under the rights described in 29 CFR 2590.701-6 or 45 CFR 146.…
79 FR 8544 — Shared Responsibility for Employers Regarding Health Coverage IRCFinal Rules (FR)Feb 12, 2014
ough 9834). Currently the definition of the term
waiting period
at § 54.9801-2 contains a cross reference to the definition of the term
waiting period at § 54.9801-3(a)(3)(iii). Proposed regulations published March 21, 2013, 78 FR 17313, would amend that cross reference to refer to § 54.9815-2708(b) and to remove the d…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…& Dana P. Goldman,
Overpaying for Prescription Drugs: The Copay Clawback,
(2018),
https://schaeffer.usc.edu/research/overpaying-for-prescription-drugs/.)
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183.
Megan Thompson (2018), W
hy a Patient Paid a $285 Copay for a $40 Drug, https://www.pbs.org/newshour/health/why-a-patient-paid-a-285-copa…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCProposed Rules (FR)Proposed Mar 21, 2013
…2704T for rules prohibiting the imposition of a preexisting condition exclusion.
Par. 5.
Section 54.9801-4 is amended by removing paragraphs (a)(3) and (c), and revising paragraph (b) to read as follows:
§ 54.9801-4
Rules relating to creditable coverage.
* * * * *
(b)
Counting creditable coverage rules superseded by pr…
IRCCourt RulingsJun 23, 2025related by meaning
Memo. 2002-18, 83 T.C.M. (CCH) 1107 , 1108– 10 (imposing penalty of
$2,000 under section 6673(a)), af f’ d , 54 F. App ’ x 254 (9th Cir. 2002) ; s ee G reat - West Life Assurance Co. v. United States , 678 F.2d 180, 183
( Ct. Cl. 1982) (“The determination of where income is derived or
‘sourced’ is generally of no mome…
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 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…