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41. Treas. Reg. § 1.72-9 — Tables.
    IRCRegulationsJul 26, 2016
    …2.7 2.6 2.4 108 3.9 3.7 3.5 3.3 3.1 3.0 2.8 2.7 2.5 2.3 109 3.8 3.6 3.4 3.3 3.1 2.9 2.7 2.6 2.4 2.3 110 3.8 3.6 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.2 111 3.8 3.5 3.3 3.2 3.0 2.8 2.6 2.4 2.3 2.1 112 3.7 3.5 3.3 3.1 2.9 2.8 2.6 2.4 2.2 2.1 113 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.4 2.2 2.0 114 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.3 2.1 2.0 …
42. 79 FR 59130 — Amendments to Excepted Benefits
    IRCFinal Rules (FR)Oct 1, 2014
    … no cost sharing under the employee assistance program. * * * * * Footnotes 1.  Public Law 104-204, 110 Stat. 2944 (September 26, 1996). Back to Citation 2.  Public Law 110-343, 122 Stat. 3881 (October 3, 2008). Back to Citation 3.  Public Law 104-204, 110 Stat. 2935 (September 26, 1996). Back to Citation 4.  Public La…
43. T.C. Memo. 2014-73 — Gina B. Weaver-Adams v. Commissioner
    IRCCourt RulingsApr 28, 2014related by meaning
    re are circumstances where the transfer of a spouse's interest in an individual retirement account, individual retirement annuity or a retirement bond incident to divorce, is not considered to be a distribution or a taxable transfer by a spouse to a former spouse. See sec. 1.408-4(g), Income Tax Regs. This is limited t…
44. T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b…
    IRCTreasury DecisionsDec 7, 2015
    …e service: one has agreed to accept $85, two have agreed to accept $100, two have agreed to accept $110, three have agreed to accept $120, and one has agreed to accept $150. Under the agreement, the plan agrees to pay the providers 80% of the agreed amount, with the individual receiving the service responsible for the …
45. PLR 201440022 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsOct 3, 2014related by meaning
    …xxxx Xxxxxxxx Xxxxxxxx This ruling will be made available for public inspection under Code section 6110 after certain deletions of identifying information are made. For details, see enclosed Notice 437, Notice of Intention to Disclose. A copy of this ruling with deletions that we intend to make available for public ins…
46. Notice 2009-22 — Asset valuation under section 430(g)(3)(B) as amended by WRERA. This notice provides interim rules regarding asset valuation methods that are permitted to be u…
    IRCNoticesApr 6, 2009
    …used as the limitation on the assumed rate of return for the plan year. D. Application of the 90 to 110 percent corridor. The rules for accounting for contribution receipts under § 430(g)(4) are applied prior to the application of the 90 to 110 percent corridor under § 430(g)(3)(B)(iii). Thus, for example, in the case …
47. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    470 in petitioner's deductions, a $144 decrease in petitioner's withholding credits, and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent Spolse Relief, seeking equitable relief from liability under the provisions of section 66(c). Respondent determ…
48. Treas. Reg. § 1.409(p)-1T(h) — Prohibited allocations of securities in an S corporation (temporary).
    IRCRegulationsMay 18, 2016
    …t, as shown in column 4 of the table in this example 2, individuals E and F have options to acquire 110 and 130 shares, respectively, of the common stock of X from X: 1Shareholders 2Deemed-ownedESOP shares(total of 1,000) 3Percentage deemed-owned ESOP shares 4Options(240) 5Shareholder percentage of deemed-owned ESOP pl…
49. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
50. Treas. Reg. § 1.412(c)(1)-2(g)(6) — Shortfall method.
    IRCRegulationsSep 9, 2016
    …1978 (1,682) 17. Total annual computation charges 173,364 180,046 183,364 18. Estimated base units* 110,000 110,000 110,000 19. Estimated unit charge (line 17 ÷ line 18) 1.576 1.637 1.667 20. Actual units during year* 105,000 110,000 105,000 21. Net shortfall charge for year (line 19 × line 20) 165,480 180,070 175,035 …
51. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    general tax credit (sec. 42), which apparently was taken into account by respondent in his assertion of an increased deficiency and additions to tax. Respondent concedes that, if the 32-page document filed by petitioners with respondent for 1977 constitutes an income tax return for purposes of sec. 6651(a), then the r…
52. T.C. Memo. 2014-31 — K.H. Company, LLC Employee Stock Ownership Plan v. Commissioner
    IRCCourt RulingsFeb 24, 2014
    …Trust v. Commissioner, at *9-*10. - 20 - [*20] 3. Special Rules for Veterans SBJPA sec. 1704(n)(1), 110 Stat. at 1883, added section 414(u), which restores certain pension benefits, profit-sharing benefits, and similar benefits that would have accrued but for the employee's absence due to "qualified military service." …
53. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    eof) in the taxable period. The tax imposed by this subsection shall be paid by any disqualified person who participates in the prohibited transaction (other than a fiduciary acting only as such). (b) Additional Taxes on Disqualified Person.-- In any case in which an initial tax is imposed by subsection (a) on a prohib…
54. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    …rdance with 26 CFR 54.9816-4T(b)(3)(ii) and (iii), 29 CFR 2590.716-4(b)(3)(ii) and (iii), and § 149.110(b)(3)(ii) and (iii), as applicable). (2) A nonparticipating provider must not bill, and must not hold liable, the participant, beneficiary, or enrollee for a payment amount for an emergency service (as defined in 26 …
55. T.C. Memo. 2010-262 — Hal Hollingsworth v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    aritable contributions within the meaning of section 170; and (5) whether petitioner is liable for an accuracy-related penalty under. section 6662(a). Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for the year at issue, and all Rule references are …
56. 81 FR 75316 — Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance
    IRCFinal Rules (FR)Oct 31, 2016
    … plan (as described in § 146.145(b)(5)(i)(C) of this subchapter). Footnotes 1.  Public Law 104-204, 110 Stat. 2944 (September 26, 1996). Back to Citation 2.  Public Law 110-343, 122 Stat. 3881 (October 3, 2008). Back to Citation 3.  Public Law 104-204, 110 Stat. 2935 (September 26, 1996). Back to Citation 4.  Public La…
57. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
58. 161 T.C. No. 6 — Estate of James E. Caan, Deceased, Jacaan Administrative Trust, Scott Caan, Trustee, Special Administrator v. Commissioner
    IRCCourt RulingsNov 14, 2023
    … be nontaxable as a rollover contribution. See I.R.C. § 408(d)(3)(A)(i); Lemishow v. Commissioner , 110 T.C. 110, 113 (1998) , supplemented by 110 T.C. 346 (1998) ; Treas. Reg. § 1.408-4(b)(1). Held : The P&A Interest was distributed to D in tax year 2015 within the meaning of I.R.C. § 408(d)(1). Held, further , the P&…
59. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    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…
60. T.C. Summary Opinion 2006-170 — Nader Ghazitehrani and Farzaneh Zamanizadeh v. Commissioner
    IRCCourt RulingsOct 23, 2006related by meaning
    ng, An appropriate decisio n will be entered . UNITED STATES TAX COURT WASHINGTON , D .C . 20217-000 2 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 IIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII I 7004 1160 0000 9602 408 2 GHAZ100 NOTIFY 3E __ GHAZ I T EHRAN , . 2404 SE 1'61a j VANCOWER W , ,~ 56 150« 02 : .1/02/06 EW W A…