89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction IRCProposed Rules (FR)Proposed Mar 25, 2024related by meaning
01:PR (REG-108761-22) room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Charles D. Wien of the Office of Associate Chief Counsel (Passthroughs & Special Industries), (202) 317-5279; concerning submissions…
IRCCourt RulingsJul 15, 1997
…ble, and (2) intended to be
payments purely for services. Elliotts, Inc. v. Commissioner
,
716 F.2d 1241, 1243 (9th Cir. 1983), revg. and remanding on
another issue T.C. Memo. 1980-282; Paula Constr. Co. v.
Commissioner
, 58 T.C. 1055, 1058 (1972), affd. without published
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMar 25, 2013
…ompensation paid in the years in
question was reasonable." Elliotts, Inc. v. Commissioner, 716 F.2d 1241, 1247
(9th Cir. 1983), rev'g T.C. Memo. 1980-282.
Petitioner's employee handbook, in place since 2002, provides that
petitioner's president determined all salary matters and J. Lipsmeyer made the
determinations. Pet…
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
or lack of jurisdiction.
Appropriate orders will be issued.
Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
Joint BoardRegulationsApr 1, 1997
…Treasury pursuant to section 3041 of the Employee Retirement Income Security Act of 1974 (29 U.S.C. 1241). Bylaws of the Board have been issued by the two Secretaries. 1 1 Copy filed with the Office of the Federal Register. Copies may also be obtained from the Executive Director of the Board.
IRCPrivate Letter RulingsDec 1, 2006related by meaning
c Oil Producing Co. v. United States
, 35 F. Supp. 766 (Ct.
Cl. 1940)). Further, an ov erpayment of tax can exist only if the amount remitted with the request for an extension of time to file exceeds the final tax liability shown on Form 706. Id.
Section 7422 authorizes a taxpayer to institute a civil action for refund…
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…
IRCPrivate Letter RulingsMar 2, 2001related by meaning
n believes a court would find section 4975 to be punitive in nature
and, therefore, considered a penalty under the Bankruptcy Code. See
, e.g. , In re MMR Holding Corp. , 1998 Bankr. LEXIS 1132 (Bankr. M.D. La. 1998) (for purposes
of I.R.C. § 6601, section 4975(a) is a penalty because its aim is to punish wrongful
cond…
78 FR 13797 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements ERISAFinal Rules (FR)Mar 1, 2013related by meaning
onstitution, the Secretary will generally obtain judicial authorization before issuing a summary seizure order. (See
Colonnade Catering Corp.
v.
U.S., 397 U.S. 72 (1970): “Where Congress has authorized inspection but made no rules governing the procedures that inspectors must follow, the Fourth Amendment and its variou…
76 FR 17762 — Regulations Governing the Performance of Actuarial Services Under the Employee Retirement Income Security Act of 1974 Joint BoardFinal Rules (FR)Mar 31, 2011
…d in part as follows:
Authority:
These rules are issued under authority of 88 Stat. 1002; 29 U.S.C. 1241, 1242.
See also5 U.S.C. 301; 31 U.S.C. 330; and 31 U.S.C. 321.
§ 901.0
[Amended]
Par. 2.
Section 901.0 is amended by removing the phrase “subpart D of this part is reserved and will set forth” and adding in its plac…
IRCCourt RulingsAug 13, 1990related by meaning
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
90 FR 40231 — Continuing Professional Education Requirements of the Joint Board for the Enrollment of Actuaries Joint BoardFinal Rules (FR)Aug 19, 2025
…42, subtitle C, title 3, Employee Retirement Income Security Act of 1974. (88 Stat. 1002, 29 U.S.C. 1241, 1242) * * *
Par. 2.
Section 901.11 is amended by:
1. Revising paragraphs (f)(2)(i)(D) and (f)(2)(ii)(A);
2. In paragraph (f)(2)(ii)(B), removing “and the instructor is in the physical presence of at least three oth…
IRCCourt RulingsJan 12, 1998related by meaning
the deduction would frustrate a sharply defined
Federal or State policy. Wood v. United States
, 863 F.2d 417
(5th Cir. 1989); Fuller v. Commissioner , 213 F.2d 102 (10th Cir.
1954), affg. 20 T.C. 308 (1953); Holmes Enterprises v.
Commissioner
, 69 T.C. 114 (1977). The test of nondeductibility
is the severity and imme…
IRCCourt RulingsNov 17, 2016related by meaning
tion 6011(a) requires that any person made liable for a tax or with
respect to its collection "shall make a return or statement according to the forms and regulations prescribed by the [Treasury] Secretary." "The return or statement
shall include therein the information required by the applicable regulations or
forms."…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…demic: Considerations for Payers and Employers,
36(7) American Journal of Health Promotion pp. 1237-1241 (2022).
Back to Citation
359.
Congressional Research Service,
Federal Telehealth Flexibilities in Private Health Insurance During the COVID-19 Public Health Emergency: In Brief
(2023),
https://crsreports.congress.g…
24 T.C. 460 — Northwest Automatic Products Corp. v. United States IRCCourt RulingsJun 23, 1955related by meaning
a determination of whether we had jurisdiction or not once it should be held that the method prescribed by statute is not the exclusive method. * * * See also, Henry Wilson, 16 B. T. A. 1280 (1929); William M. Greve, 37 B. T. A. 450 (1938); John A. Gebelein, Inc., 37 B. T. A. 605 (1938); Oscar Block, 2 T. C. 761 (1943…
IRCProposed Rules (FR)Proposed Oct 5, 2022
…of the Treasury to establish a Joint Board for the Enrollment of Actuaries (Joint Board). 29 U.S.C. 1241. The Joint Board consists of three members and one alternate member appointed by the Secretary of the Treasury, two members and one alternate member appointed by the Secretary of Labor, and one non-voting representa…
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
ection is applicable on July 6, 2007.
§ 54.6011-1T
[Amended]
Par. 10. Section § 54.6011-1T(c) & (d) are removed.
PART 301—PROCEDURE AND ADMINISTRATION Par. 11. The authority citation for part 301 continues to read, in part, as follows:
Authority:
26 U.S.C. 7805 * * *
Par. 12. Section 301.6011(g)-1 is added to read as f…