IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
- 23 -
(3) If at any time the correction of the
error is authorized as to one such t…
79 FR 51118 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Aug 27, 2014
…the preamble, the Department of Health and Human Services proposes to amend 45 CFR subtitle A, part 147 as follows:
PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSRUANCE MARKETS
1. The authority citation for part 147 continues to read as follows:
Authority:
Secs 2701 through 2763, …
IRCCourt RulingsFeb 22, 1989related by meaning
ate for respondent to change his position 6 months after the start of the trial and after all of petitioners’ witnesses had completed their testimony. On brief, respondent continues to argue section 131(c)(3)(B)(ii)(I) of R.A. 1978, as amended by section 252 of TEFRA; we continue to refuse to consider that argument in …
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
6.46 6.68
H. Normal cost (beginning of year)
3
7,557,754 8,682,914 9,523,819 11,286,962
I. Benefits paid during year N/A 4,078,160 4,859,441 5,301,930 J. Employee contributions during year N/A 473,833 736,176 784,906
K. Interest to yearend
4
498,812 896,239 1,225,134 1,454,591
L. Account limit (yearend)
5
8,056,566 14,…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
IRCCourt RulingsApr 16, 2020
on payments of $30,557 for 2010, and respondent has conceded that this
amount is not subject to the additional tax. The record contains no evidence of additional qualified education expenses paid for 2010 or any qualified education
expenses paid for 2011.¹5
Accordingly, we find petitioners liable for the 10% additional…
U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner IRCCourt RulingsJun 26, 2018
…1 (defined as the plan year and
limitation year in the ESOP's plan document). Mr. Essy received $41,557 and
$40,000 in wages in the 2000 and 2001 calendar years, respectively. There is no
information regarding the amount Mr. Essy specifically earned during the 12month limitation year from April 1, 2000, to March 31, 20…
IRCCourt RulingsApr 2, 2020
…ne 19.b, and the interest due was shown on line 19.c. For 2003, line 19.a showed the
tax due as $10,557; line 19.b (for penalties) was blank; and line 19.c showed the
interest due "computed to 05/29/2011" as zero (specifically "0.00"). The sum of
all three amounts due was shown as $10,557. For 2004, line 19.a showed th…
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…
IRCCourt RulingsMay 14, 2009related by meaning
acknowledgmen t
of their alleged charitable contribution . See sec . 170 (f ) (8) (A) .
Accordingly, we hold that petitioners are not entitled to the charitable contribution deduction claimed on their 2004 Federal
income tax return .
Section 6673 Penalt y
Respondent requests imposition of a penalty pursuant to
section…
72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner IRCCourt RulingsJun 11, 1979related by meaning
ensation may not avoid taxation by anticipatory arrangements regardless of their technical elegance. United States v. Basye, 410 U.S. 441, 450 (1973). In Armantrout v. Commissioner, 570 F.2d 210 (7th Cir. 1978), affg. per curiam 67 T.C. 996 (1977), an employer paid sums to a trustee who, in turn, paid school expenses f…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
….
Back to Citation
13.
26 CFR 54.9815-2715(a)(4)(ii)(A), 29 CFR 2590.715-2715(a)(4)(ii)(A), 45 CFR 147.200(a)(4)(ii)(A).
Back to Citation
14. 26 CFR 54.9815-2715(a)(4)(ii)(B), 29 CFR 2590.715-2715(a)(4)(ii)(B), 45 CFR 147.200(a)(4)(ii)(B).
Back to Citation
15.
85 FR 72158 (Nov. 12, 2020).
See also
On December 23, 20…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…s stated in the preamble, the Department of Health and Human Services proposes to amend 45 CFR part 147 as set forth below:
PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS
9. The authority citation for part 147 is revised to read as follows:
Authority:
42 U.S.C. 300gg…
IRCProposed Rules (FR)Proposed Feb 24, 2014
… in the preamble, the Department of Health and Human Services proposes to further amend 45 CFR part 147, as amended by the final rule titled, Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act, published elsewhere in this issue of the
Fede…
78 FR 8456 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 6, 2013
…the preamble, the Department of Health and Human Services proposes to amend 45 CFR Subtitle A parts 147, 148, and 156 as follows:
PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS
1. The authority citation for part 147 continues to read as follows:
Authority:
2701 throu…
IRCCourt RulingsMay 23, 1979related by meaning
rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
76 FR 37208 — Group Health Plans and Health Insurance Issuers: Rules Relating to Internal Claims and Appeals and External Review Processes IRCFinal Rules (FR)Jun 24, 2011
… the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR part 147 as follows:
PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS
1. The authority citation for part 147 continues to read as follows:
Authority:
Sections 2701 through 27…
76 FR 46621 — Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable Care Act IRCFinal Rules (FR)Aug 3, 2011
… the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR part 147 as follows: PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS
1. The authority citation for part 147 continues to read as follows:
Authority:
2701 through 2763, 2791,…
IRCCourt RulingsFeb 22, 1999related by meaning
on? We
hold that it does.
2. Did petitioners, within the meaning of section
4975(f)(5), correct the prohibited transaction? We hold that
they did not. 3. What is the "amount involved" relating to a loan that is
subject to section 4975 excise taxes? We hold that the "amount
involved" is the greater of the interest paid …
75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable… IRCFinal Rules (FR)Jul 19, 2010
… the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR part 147, added May 13, 2010, at 75 FR 27138, effective July 12, 2010, as follows:
PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS
1. The authority citation for part 147 con…