IRCCourt RulingsJul 18, 1968related by meaning
62 (or sec. 404) and under other provisions, such as interest tolvich is specifically allowable as a deduction under section 16$. [Emphasis supplied.] H. Rept. No. 749, 88th Cong., 1st Sess. p. 82 (1968). See also H. Rept. No. 749, p. A92 (1963).
In view of these statutory changes, McNutt-Boyce Co., supra, is no longer…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…mail
Printing cost per notice
Total costs
(A)
(B)
(C) = (A × B)
(D)
(E) = (C × D)
First Year
* 68,134,832
100.0
68,134,832
$0.20
$13,626,966
Second Year
32,650,854
100.0
32,650,854
0.20
6,530,171
Third Year
32,650,854
100.0
32,650,854
0.20
6,530,171
Three-Year Average
44,478,847
44,478,847
$8,895,769
Note:
IRCCourt RulingsOct 9, 1997related by meaning
nd contribution, made
during December 1986, would be deductible in 1986, because that
contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986.
Accordingly, petitioner argues, the regulation contradicts the
plain language of section 419 and is invalid. Petiti…
IRCPrivate Letter RulingsJul 26, 2024
…n 2301 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act),
Pub . L. No. 116-136, 134 Stat. 281 (Mar. 27, 2020), as amended by section 206 of the Taxpayer
Certainty and Disaster Tax Relief Act (Relief Act), which was e nacted as Division EE of the Consolidated
Appropriations Act, 2021, Pub. L. No. 116…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
… . .applying the
standard enunciated by the Supreme Court in Skidmore v . Swift &
Co . , 323 U .S . 134, 140 (1944), the weight (if any) that we affor d
them depends upon their persuasiveness and the consistency of the
Commissioner's position over time . See PSB Holdings, Inc . v .
Commissioner , 129 T .C . 131, 142 (2…
IRCCourt RulingsApr 2, 2024
…422; Williams
Packing & Navigation Co. , 370 U.S. at 7 – 8; Hallmark Rsch. Collective ,
159 T.C. at 134. In a deficiency proceeding before this Court, taxpayers
are afforded the oppo rtunity to seek prepayment de novo review of the
IRS’s deficiency determination. Hallmark Rsch. Collective , 159 T.C. at
134, 165. But re…
IRCCourt RulingsJun 1, 1987related by meaning
…in most respects, but the ERISA term includes a somewhat broader range of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468.
See generally Capital City Excavating Co. v. Commissioner, T.C. Memo. 1984-193.
Sec. 407 of EEISA provides as follows:
Sec. 407(a) Except as otherwise provided in this section an…
IRCCourt RulingsFeb 22, 2010
134 T .C . No . 6
UNITED STATES TAX COUR T
KARL L . MATTHIES AND DEBORAH MATTHIES , Petitioners v .
COMMISSIONER OF INTERNAL REVENUE, Responden t
Docket No . 22196-07 .
Filed February 22, 2010 .
A profit-sharing plan of Ps' wholly owned S
corporation bought a life insurance policy on Ps' lives
with funds rolled over fr…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
IRCCourt RulingsMay 3, 1995related by meaning
; General Signal Corp. v. Commissioner, supra at 240; U.S. Padding Corp. v. Commissioner, 88 T.C. 177, 184 (1987), affd. 865 F.2d 750 (6th Cir. 1989). Prior to the Deficit Reduction Act of 1984 (defra), Pub. L. 98-369, 98 Stat. 494, taxpayers could obtain deductions for contributions paid or accrued to welfare benefit …
85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020 ERISAFinal Rules (FR)Jan 15, 2020
…ry text
January 23, 2019
January 15, 2020.
§ 1903.15(d)(1)
$9,472
$9,639. § 1903.15(d)(1)
$132,598
$134,937.
§ 1903.15(d)(2)
$132,598
$134,937.
§ 1903.15(d)(3)
$13,260
$13,494.
§ 1903.15(d)(4)
$13,260
$13,494.
§ 1903.15(d)(5)
$13,260
$13,494.
§ 1903.15(d)(6)
$13,260
$13,494.
DEPARTMENT OF LABOR
Mine Safety and Health A…
IRCCourt RulingsMar 11, 2020related by meaning
little more than guesswork and failed to satisfy the strict substantiation
requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan
v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section
274(d). Cons…
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
IRCCourt RulingsFeb 15, 1979related by meaning
loyees, which have less generous plans or no plans at all, this would generally constitute an impermissable discrimination. * * * [Emphasis supplied.] We believe that a fair reading of section 414(b) would have alerted petitioner to the fact that such section requires, inter alia, that an affiliated group- comprised of…
79 FR 51092 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Aug 27, 2014
…014).
On June 30, 2014, the Supreme Court ruled in the case of
Burwell
v.
Hobby Lobby Stores, Inc., 134 S. Ct. 2751 (2014), that, under the Religious Freedom Restoration Act of 1993 (RFRA), the requirement to provide contraceptive coverage could not be applied to the closely held for-profit corporations before the Cour…
88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 2, 2023
… (November 2018 Religious Exemption final rules).
Back to Citation
7.
Wheaton College
v.
Burwell,
134 S. Ct. 2806, 573 U.S. 958, 189 L. Ed. 2d 856 (2014).
Back to Citation
8.
Burwell
v.
Hobby Lobby Stores, Inc.,
134 S. Ct. 2751, 573 U.S. 682, 189 L. Ed. 2d 675 (2014).
Back to Citation
9.
Zubik
v.
Burwell,
136 S. …
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
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
…fore increases the daily base penalty for operators employing fewer than 25 employees from $100 to $134; increases the daily base penalty for operators employing 25 to 50 employees from $200 to $268; increases the daily base penalty for operators employing 51 to 100 employees from $300 to $402; increases the daily base…
IRCCourt RulingsJun 3, 1998related by meaning
been finalized. Moreover, even if the
proposed regulation were final, it would not, by its terms,
apply to the 1986 loans. See sec. 1.72(p)-1, Q&A-19, Proposed Income Tax Regs. 63 Fed. Reg. 42, 47 (Jan. 2,
1998) (regulation applies to "loans made on or after the
date that is three months after the date of publication o…