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 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…
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…
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 RulingsJul 25, 2005related by meaning
settlement
agreement is not a qualified domestic order, and Mr. Ahmad is not
an alternate payee, the exception in section 72(t)(2)(C) is
inapplicable. In light of the foregoing, the Court holds that petitioners
are liable for the 10-percent additional tax imposed under
section 72(t).
Reviewed and adopted as the report …
IRCFinal Rules (FR)Oct 1, 2014
… the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR part 146 as set forth below:
PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET
5. The authority citation for part 146 continues to read as follows:
Authority:
Secs. 2702 through 2705, 2711 through 2723, 2791, and 27…
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 RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
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 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)…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
IRCCourt RulingsDec 23, 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
Practice and Procedure.
T.C. Memo. 1996-556
UNITED STATES TAX COURT
ALFRED P. DUFFY, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respo…
IRCFinal Rules (FR)Mar 18, 2015
… the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR part 146 as set forth below:
PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET
5. The authority citation for part 146 continues to read as follows:
Authority:
Secs. 2702 through 2705, 2711 through 2723, 2791, and 27…
IRCCourt RulingsSep 29, 1992related by meaning
etitioner Docket No. Year ended Deficiency Sec. 6651(a)(1) Sec. 6659A
Citrus Valley Estates, Ine. et al. 12900-89 12/31/82 $6,182.00
12/31/83 5,737.00 12/31/85 22,462.00
24352-90 12/31/88 4,265.00 - - - $1,280.00
Additions to tax
Petitioner Docket No. Year ended Deficiency Sec. 6651(a)(1) Sec. 6659A
Robert J. & Janice …
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…
IRCCourt RulingsApr 20, 2017related by meaning
See Parker v. Commissioner, T.C. Memo. 2012-66, 103
T.C.M. (CCH) 1321, 1323 (finding section 6201(d) inapplicable where the tax-
(continued...)
- 10 - [*10] Petitioner has not satisfied his burden of proof. He failed in his petition to
assign error to any of respondent's determinations, asserting instead that he had no…