IRCCourt RulingsOct 17, 1995
…466, 468 (9th Cir. 1994); Shimota v. United
States
, 21 Cl. Ct. 510, 519-520 (1990), affd. 943 F.2d 1312 (Fed.
Cir. 1991); sec. 1.72-2(a)(3)(iii), Income Tax Regs. A lump sum
payment from the CSRS is treated as a payment under an annuity
contract. Roundy v. Commissioner
, T.C. Memo. 1995-298; Kirkland
v. Commissioner
,…
IRCCode / StatuteJan 5, 2023related by meaning
(d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and
(d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer.
(d)(2)(C) (C) Reduction not to apply to tax shelters
(d)(…
IRCCourt RulingsJan 6, 1997
…2; Green v.
Commissioner
, supra
; Shimota v. United States
, 21 Cl. Ct. 510
(1990), affd. 943 F.2d 1312 (Fed. Cir. 1991). We have carefully
considered petitioners' other arguments and have concluded that
they cannot prevail against the above decisions, even though, to
some extent, they have differing strands of reason…
82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017 ERISAFinal Rules (FR)Jan 18, 2017
… 412(e), Pub. L. 105-277, 112 Stat. 2681 (8 U.S.C. 1182 note); sec. 2(d), Pub. L. 106-95, 113 Stat. 1312, 1316 (8 U.S.C. 1182 note); 29 U.S.C. 49k; Pub. L. 107-296, 116 Stat. 2135, as amended; Pub. L. 109-423, 120 Stat. 2900; 8 CFR 214.2(h)(4)(i); and 8 CFR 214.2(h)(6)(iii).
Subpart A issued under 8 CFR 214.2(h).
Subpa…
IRCCourt RulingsSep 23, 2014
…122 F.3d 835 (9th Cir. 1997);
Shimota v. United States, 21 C1. Ct. 510, 519 (1990), aff'd, 943 F.2d 1312 (Fed.
Cir. 1991).
2Respondent also contends that petitioner's deposit to CSRS is not a
rollover because the funds paid to CSRS were not a distribution from an IRA. We
have held that the phrase "if the entire amount …
IRCCourt RulingsMar 12, 2015related by meaning
nd.8
SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265
(2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden
of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg
g, Hyd…
IRCCourt RulingsJul 11, 2024
…o reason to hold differently here . See Reimels, 123 T.C.
at 247 – 48; Bradley , 62 T.C.M. (CCH) at 1312. Petitioners may not
exclude any portion of th e benefits they received from the RRB from
their gross income on the basis of disability. Cf. Gibson v.
11
In an effort to bolster his position , Mr. Tuma d oes point t…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021related by meaning
lve the complaint.
Department of the Treasury
Internal Revenue Service
Accordingly, 26 CFR part 54 is amended as follows:
PART 54—PENSION EXCISE TAXES Paragraph 4. The authority citation for part 54 continues to read, in part, as follows:
Authority:
26 U.S.C. 7805, unless otherwise noted.
* * * * *
Par. 5. Section 54.9…
IRCProposed Rules (FR)Proposed Feb 18, 2025related by meaning
ration) by email at publichearings@irs.gov (preferred) or by telephone at (202) 317-6901 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Authority These proposed regulations are issued under the express delegation of authority under section 7805 of the Code. Section 7805(a) directs the Secretary of the Treasury or …
ERISADOL Technical ReleasesSep 13, 2013
…ith respect to any employee if the employee’s employer is a qualified employer (as defined in ACA § 1312(f)(2)) offering the employee the opportunity to enroll through an Exchange in a qualified health plan in a group market. See Code § 125(f)(3)(B).
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
of electronic form for financial institutions filing Form 1042, Form 1042-S, or Form 8966.
* * * * *
(d) * * *
(1) Magnetic media or electronic form. * * * * *
(e) Applicability date.
Par. 4. Section 1.1474-1 is amended by revising paragraphs (e) and (j) to read as follows:
§ 1.1474-1
Liability for withheld tax and wi…
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 RulingsNov 25, 2008related by meaning
e Tax Court
(and the Tax Court shall have
jurisdiction) to determine the
appropriate relief available to the
individual under this section * * *
- 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4
This amendment applies "with respect to liability for taxes
arising or remaining unpaid on or after …
85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020 ERISAFinal Rules (FR)Jan 15, 2020
… 412(e), Pub. L. 105-277, 112 Stat. 2681 (8 U.S.C. 1182 note); sec. 2(d), Pub. L. 106-95, 113 Stat. 1312, 1316 (8 U.S.C. 1182 note); 29 U.S.C. 49k; Pub. L. 107-296, 116 Stat. 2135, as amended; Pub. L. 109-423, 120 Stat. 2900; 8 CFR 214.2(h)(4)(i); and 8 CFR 214.2(h)(6)(iii); and sec. 6, Pub. L. 115-128, 132 Stat. 1547 …
80 FR 54980 — Reportable Events and Certain Other Notification Requirements PBGCFinal Rules (FR)Sep 11, 2015related by meaning
added to the aggregate unpaid balance of all preceding such payments for which payment was not made when due (including interest), exceeds $1 million. (1) Form 200 must be filed with PBGC no later than 10 days after the due date for any required payment for which payment was not made when due.
(2) If a contributing spo…
88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac… IRCProposed Rules (FR)Proposed Jul 12, 2023
…7);
see also69 FR 78720 (December 30, 2004).
Back to Citation
15.
See Public Law 111-148, section 1312(c)(1) and 45 CFR 156.80.
Back to Citation
16.
81 FR 38019 (June 10, 2016).
Back to Citation
17.
81 FR 75316 (October 31, 2016).
Back to Citation
18.
Id.
at 75317-75318.
Back to Citation
19.
Id.
Back to Citatio…
89 FR 34106 — Definition of “Employer”-Association Health Plans ERISAFinal Rules (FR)Apr 30, 2024
…lling individuals in such coverage.
16.
See section 2701 of the PHS Act (premium rating), section 1312(c) of the ACA (single risk pool), and section 2707(a) of the PHS Act (EHB requirements). The ACA requires non-grandfathered health plans in the individual and small group markets to cover EHBs, which include items a…
IRCCourt RulingsFeb 29, 2012related by meaning
urd result. We agree. ,It is a well-established canon of statutory .
interpretation that "'identical words used in different parts of the same act are intended to have the same meaning."' United States Nat'l Bank of Or: v. Indep.
Ins. Agents of Am:, Inc., 508 U.S. 439/460 (1993) (quoting Commissioner v.
Keystone Consol…
ERISARegulationsJan 1, 2017related by meaning
(j) (j) Liability.
(j)(1) (1) If more than one person is responsible as administrator for the failure to file the annual report, all such persons shall be jointly and severally liable with respect to such failure.
(j)(2) (2) Any person against whom a civil penalty has been assessed under section 502(c)(2) pursuant to a…
87 FR 80042 — Exception for Interests Held by Foreign Pension Funds IRCFinal Rules (FR)Dec 29, 2022related by meaning
ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development.
( printed page 80055) List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended a…