ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…okings Schaeffer Initiative for Health Policy, September 26, 2019. https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2019/09/26/california-saw-reduction-in-out-of-network-care-from-affected-specialties-after-2017-surprise-billing-law/.
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161.
Kliff S. Surprise medical bills,…
IRCCourt RulingsMay 19, 2011related by meaning
ion 6662(a) and (b) (2).
Generally, section 6662(a) and (b) (1) authorizes the
Commissioner to impose a 20-percent penalty on the portion of an
- 72 - underpayment of income tax attributable to negligence or
disregard of rules or regulations. The term "negligence"
includes any failure to make.a reasonable attempt to co…
IRCCourt RulingsMay 5, 1998
…lidated for trial, briefing,
and opinion by order of this Court dated May 27, 1997.
T.C. Memo. 1998-164
UNITED STATES TAX COURT
PRINDLE INTERNATIONAL MARKETING, UBO,
KEYUS GROUP, TRUSTEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
ROLAND R. AND VIRGINIA A. FOX, Petitioners v
.
COMMISSIONER OF INTERNAL …
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
164 T.C. at 151.
When applied to vacant land, the approach can be highly sensitive to
assumptions, and unsupported projections have undermined income an alyses in many conservation easement cases. See, e.g., Savannah
Shoals, T.C. Memo. 2024-35, at *36 (“Income valuation methods are not
favored when valuing vacant land…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…he net present value of a hypothetical limestone business
conducted on the land. See Ranch Springs, 164 T.C. at 151– 53;
Beaverdam Creek , T.C . Memo, 2025- 53, at *36. Even if we were to
conclude that the highest and best use of the Property w as as a
limestone mine, Mr. Catlett’s before value of $34,540,000 would fai…
IRCCourt RulingsDec 2, 2013related by meaning
or disbarment of any practitioner". 31
C.F.R. sec. 10.4(a)(2007).
- 6 -
or the Form 1099-R issued by Guardian.5 After preparing the return, Mr. Neuman reviewed it with petitioners, who then timely filed it.
In March 2012 respondent issued to petitioners a notice of deficiency for
2010, determining a deficiency of $6,94…
85 FR 66219 — Effect of Section 67(g) on Trusts and Estates IRCFinal Rules (FR)Oct 19, 2020
…id $25,000 of state income tax, for which the trust is limited to a $10,000 deduction under section 164(b)(6)(B) for taxable years beginning after December 31, 2017, and before January 1, 2026. In the commenter's example, the entire amount of the allowable $10,000 deduction was passed through to the beneficiary as an e…
IRCRegulationsJul 26, 2016
…th is 12.6, and the total number of unit payments anticipatable (on an annual basis) is, therefore, 164.4 (2 × 12.6 plus 139.2). Dividing the difference previously found ($328.80) by the total number of unit payments thus determined (164.4) indicates that A will have an additional allocation of the investment in the co…
IRCRegulationsMay 18, 2016
…1.408-2(e)(5)(ii)(B) is determined as follows for Trustee X: (1) four percent of $4,100,000 equals $164,000; (2) two percent of $1,400,000 equals $28,000; and (3) $164,000 minus $28,000 equals $136,000. Thus, because $136,000 exceeds $100,000, the minimum net worth necessary for Trustee X to accept new accounts for 199…
IRCCourt RulingsApr 20, 2017related by meaning
ish the tax shown on the taxpayer's return for the preceding year or
demonstrate that the taxpayer filed no such return. See Wheeler, 127 T.C. at 212; Schlussel v. Commissioner, T.C. Memo. 2013-185.
Respondent met his burden of production by including with his summary
judgment motion a redacted Form 4340 showing that p…
IRCRegulationsDec 30, 2016
…ermination regarding payment. For this purpose, “payment” has the meaning given such term in 45 CFR 164.501 of the privacy regulations issued under the Health Insurance Portability and Accountability Act. Thus, if a plan conditions payment for an item or service based on its medical appropriateness and the medical appr…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
… 31884, 31895.
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45.
See 29 CFR 2520.104b-31(k).
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46.
45 CFR part 164.
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47.
By contrast, if pension benefit information is transmitted via a company email, there is less concern because the employer would already be aware of the employee's deferral amount or their 401(…
IRCCourt RulingsDec 22, 2008related by meaning
foregoing quoted terms are specially defined and used
under the "Public Salary Tax Act of 1939" ;
3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor
"taxpayer," nor "non-resident alien," nor any other
"legal entity" "made liable for" or "subject to" any
"internal reve…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
…ocess ." Central Bank of Denver, N .A . v . First Interstate 'Bank of
Denver, N .A . , .511 U .S . .164, 187 (1994) . And the narrow . focus of
Congress's attention should make us even more cautious--"when, as
here, Congress has not comprehensively revised a statutory scheme
. .but has made .only"isolated amendments, w…
IRCCourt RulingsMay 30, 1984related by meaning
ents of section 2039(c)(3).
Due to concessions and in order to reflect petitioner’s claim for an overpayment,
Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
IRCCourt RulingsAug 18, 2015
T.C. Memo. 2015-164
UNITED STATES TAX COURT
EDWARD N. TOBIAS AND SUZANNE M. KOEGLER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21510-13. Filed August 18, 2015.
Edward N. Tobias and Suzanne M. Koegler, pro sese.
Kristina L. Rico, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LAUBER…
IRCCourt RulingsMay 19, 2011
…ns attributable to that trade
or business. Sec. 1402(a); sec. 1.1402(a)-1, Income Tax Regs.
Section 164(f) allows a táxpayer to deduct one-half of the selfemployment tax imposed by section 1401.
Petitioner received $92,500 in nonemployee compensation in
her capacity as a consultant for Key Apparel and Star.
Respondent …
IRCCourt RulingsJun 23, 2015related by meaning
d $3,186 of debt that petitioner owed. Petitioner did not report
- 5 -
receiving any income from the cancellation of debt. Petitioner does not dispute that the debt was discharged but rather argues that the section 108(a)(1)(B)
exclusion applies.
Discussion
I. Burden of Proof
In general, the Commiissioner's determinati…
IRCCourt RulingsMay 14, 2009
…r
.a qualifiedrresidence
interest paid deduction in 2002 for the . . alleged"payment .
- 18Section= 164 (a) (1) .generally allows . a deduction for the
payment of real property taxes for .the taxable year within which
paid . It is well established that, in ;general, taxes paid on
real property may be deducted
.as such …