IRCCourt RulingsJan 2, 2025
…to contrive a fictional debt” (quoting United States v. Uneco, Inc. ( In re Uneco, Inc. ), 532 F.2d 1204, 1207 (8th Cir. 1976))), aff’d , 521 F. App’x 476 (6th Cir.
2013).
25
[* 25] any credible documents in the record. For example, they claim
that an independent actuary firm valued NRSP Management at
$75 million in 20…
IRCCourt RulingsJul 30, 2012
…ion to capital is not considered a
debt. United States v. Uneco, Inc. (In re Uneco, Inc.), 532 F.2d 1204, 1207 (8th
Cir. 1976); sec. 1.166-1(c), Income Tax Regs. To determine whether a bona fide
debt exists, we consider objective and subjective factors. In re Uneco, Inc., 532
F.2d at 1209.
Petitioner's transfers from h…
IRCCourt RulingsJul 27, 2004
… residence. Petitioners’
settlement statement concerning the sale of their residence
listed on line 1204: “Government Recording and Transfer
Charges: Excise Tax $12,068.” After the sale of their residence,
petitioners relocated to Portland, Oregon.
B. IRA Distribution
During the year in issue, petitioners had one daugh…
ERISACode / StatuteJan 6, 2017related by meaning
(d)(6)(A) (A) Motions to postpone, made with respect to the discharge from committee or the consideration of a resolution of disapproval, and motions to proceed to the consideration of other business, shall be decided without debate.
(d)(6)(B) (B) Appeals from the decisions of the Chair relating to the application of t…
IRCCourt RulingsNov 15, 2004
…sury Department and the Labor Department) affects the instant
case. See 29 U.S.C. 1106, 1108, 1203, 1204. Accordingly, we
assume that all requirements as to notification of, and
coordination with, the Labor Department have been complied with.
- 21 -
Fiduciary responsibility rules, in general
The conference substitute e…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, the following shall apply in lieu of § 18.9 of this title.
ERISADOL Technical ReleasesSep 18, 2013
…ther in order to, among other things, reduce conflicting requirements. ERISA § 3004(a); 29 U.S.C. § 1204(a). The Department has coordinated with Treasury/IRS and HHS in developing this Technical Release, and agreed with those agencies that recognition of "spouses" and "marriages" based on the validity of the marriage i…
75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Jul 6, 2010related by meaning
to the transaction on or before the first date on which the transaction is required to be disclosed by the person under section 6011.
Special Analyses It has been determined that this Treasury decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not …
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Sub…
84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…2(c)(5)(i)(C), and 45 CFR 146.145(b)(5)(i)(C).
Back to Citation
210.
IRS Notice 2005-42, 2005-1 CB 1204 and IRS Notice 2013-71, 2013-47 IRB 532.
Back to Citation
211.
See
Code sections 125(i) and 223(g).
Back to Citation
212.
Transfers, however, from other HRAs are not permitted.
See
the discussion earlier in this …
Notice 2020-33 — This notice increases the $500 limit for unused amounts remaining in a health FSA that may be carried over into the following year by making the carryover amou… IRCNoticesMay 26, 2020
… months and 15 days immediately following the end of the plan year. See Notice 2005-42, 2005-1 C.B. 1204, and Prop. Treas. Reg. § 1.125-1(e). This exception is based on other Code provisions and Treasury regulations that do not treat certain compensation arrangements as providing for deferred compensation if the compen…
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
…ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
Notice 2009-68 — Safe harbor explanations — eligible rollover distributions. This notice contains two safe harbor explanations that may be provided to recipients of eligible ro… IRCNoticesSep 28, 2009
…officer with the employer that maintains the plan. A public safety officer is defined under section 1204(9)(A) of the Omnibus Crime Control and Safe Streets Act of 1968 (P.L. 90-351, 42 U.S.C. 3796b(9)(A)) as “an individual serving a public agency in an official capacity, with or without compensation, as a law enforcem…
I.R.C. § 6701(c) — Penalties for aiding and abetting understatement of tax liability IRCCode / StatuteJan 4, 1995related by meaning
(c) (c) Activities of subordinates
(c)(1) (1) In general For purposes of subsection (a), the term "procures" includes—
(c)(1)(A) (A) ordering (or otherwise causing) a subordinate to do an act, and
(c)(1)(B) (B) knowing of, and not attempting to prevent, participation by a subordinate in an act.
(c)(2) (2) Subordinate F…
Notice 2007-7 — Distribution issues; multiple issues; Pension Protection Act of 2006. This notice provides guidance in the form of questions and answers with respect to certai… IRCNoticesModified Jan 29, 2007
…ement officer, a firefighter, a chaplain, or as a member of a rescue squad or ambulance crew. See § 1204(9)(A) of the Omnibus Crime Control and Safe Streets Act of 1968 (42 U.S.C. 3796b(9)(A)).
Q-22. Under what circumstances are the provisions of § 402(l) available for eligible retired public safety officers?
A-22. The…
IRCCourt RulingsApr 2, 2024related by meaning
ead, by
giving effect to every word that Congress used in the statute, it protects
taxpayers like them with the required “man datory 60-day extension” while the Secretary considers whether and how to exercise his discretion
under subsection (a). See Lowe v. SEC , 472 U.S. 181, 207 n.53 (1985);
see also Scalia & Garner …
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…ants. The grace period rules in these proposed regulations are based on Notice 2005-42, 2005-1 C.B. 1204, modified in Notice 2007-22, 2007-10 I.R.B. 670, see §601.601(d)(2)(ii)(b), amplified in Notice 2005-86, 2005-2 C.B. 1075, amplified in Notice 2007-22, 2007-10 I.R.B.
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
89 FR 12955 — Management of Federal Agency Disbursements IRCFinal Rules (FR)Feb 21, 2024related by meaning
l.treasury.gov,
or Rebecca Saltiel, Senior Counsel, at (202) 874-6648 or
Rebecca.Saltiel@fiscal.treasury.gov.
SUPPLEMENTARY INFORMATION:
I. Background In 1998, Fiscal Service issued a final rule, codified at 31 CFR part 208 (part 208), to implement the requirements of 31 U.S.C. 3332, as amended by section 31001(x)(1) o…
PBGCRegulationsJan 1, 2017
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…