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
…C.-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insurance.
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173.
See section III.B.1.c of this preamble for a discussion of the Depar…
IRCRegulationsJul 26, 2016
…ve received which is in the same ratio that 4 units bear to 10 units) and would thus have received $174.80 less than the portion of the investment in the contract allocable to each of D's taxable years. In these circumstances, D would be entitled to elect to redetermine the portion of the investment in the contract all…
IRCProposed Rules (FR)Proposed May 13, 2026
…verage of excepted fertility benefit.
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151. The estimate is calculated as: (36,384,174 participants aged 25 to 45 enrolled in non-federal, employer-sponsored health insurance without offer of fertility coverage in group plan × 65.8 percent offer rate) + (13,457,160 participants aged 25 to 45 enrolled i…
90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Aug 15, 2025related by meaning
…he affidavit requirements prescribed by the Department of Justice for perjury cases under 28 U.S.C. 1746. The new language for the affidavit must include language specifically referring to the penalty of perjury “under the laws of the United States of America” to adhere to the sample form outlined in paragraph (1) of 2…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
s pass to the
grantor . See Estate~of O'Connor v . Commissioner , supra at 174 ;
see also Hornberger v . Commissioner , T .C . Memo . 2000-42 n .5 ("A grantor trust is not subject to the income tax . Rather, all of
the income and deductions pertaining to a grantor trust must be
taken into account by the grantor ."), af…
IRCCourt RulingsAug 1, 2012
…plied. They apparently assume--erroneously--that
relaxed rules of procedure and evidence under Rule 174(b) relieve them of the necessity of timely and appropriate evidence and arguments based on applicable
law. Rule 174(b), however, refers to consistency with "orderly procedure" and
requires evidence that has "probativ…
IRCCourt RulingsSep 19, 2016
RS
T.C. Memo. 2016-174
UNITED STATES TAX COURT
JAY D. SCHECHTER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26978-12. Filed September 19, 2016.
Russell D. Stanaland, for petitioner.
Christopher J. Richmond, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MORRISON, Judge: The responden…
88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCProposed Rules (FR)Proposed Nov 20, 2023related by meaning
S corporations and other pass-through entities in the same manner as such rules apply to partnerships” except as the Secretary may otherwise provide. Section 170(h)(7)(B) defines the terms “relevant basis” and “modified basis,” section 170(h)(7)(C), (D), and (E) provide three exceptions to the Disallowance Rule, and s…
IRCCourt RulingsMay 21, 1999
…in issue.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1999-174
UNITED STATES TAX COURT
CHRYS L. UDOH, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22424-97. Filed May 21, 1999.
Chrys L. Udoh, pro se.
Lindsey D. Stellwagen
, for respondent.
MEMORANDUM OP…
IRCCourt RulingsFeb 9, 2023
…lies dominion or control of the taxpayer.
* * *
Commissioner v. First Sec . Bank , 405 U.S. at 404.
174
First Security
Bank then quoted the “complete power” sentence from 26 C.F.R. sec.
1.482-1(b)(1) (1971),
175
explaining that the “complete-power” sentence
“is consistent with the control concept heretofore approved by…
IRCCourt RulingsMay 27, 2004
… account of a prohibited transaction. S. Rept. 93-383, at
94-95 (1973), 1974-3 C.B. (Supp.) 80, 173-174. Disqualification
penalized employee/plan participants in that they were denied
favorable tax consequences such as deferral of taxation. Id.
at
94, 1974-3 C.B. (Supp.) at 173. The goal of Congress in enacting
section…
T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua… IRCTreasury DecisionsMar 7, 2016related by meaning
or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security.
T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
IRCCourt RulingsMay 13, 1965
…e distribution of such contracts upon any termination of employment. On January 5, 1959, there were 174 employees of the Funkhouser Co. under the age of 65 for whose benefit annuity contracts were held under the Funkhouser Co. pension trust agreement, as amended to include the pension trust agreement of B. J. Funkhouse…
ERISAProposed Rules (FR)Proposed Nov 21, 2022
…nt estimates that the quantified cost of the VFC Program with the Self-Correction Component is $588,174. Thus, the Department estimates that total cost savings associated with the Self-Correction Component is $206,550 ($794,724−$588,174).
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29.
Internal DOL calculation based on 2021 labor cost data. For…
86 FR 51488 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Sep 15, 2021
…rs
Costs
Hours
Costs
Pension:
Large Plans
261,464
$62,431,639.11
142,897
$31,568,313.36
Small Plans
174,999
87,694,622.39
176,481
103,113,327.32
Welfare:
Large Plans
108,142
111,593,190.83
9,953
1,811,627.38
Small Plans
6,137
5,407,649.86
2,507
1,252,295.71
Total:
Large Plans
369,607
174,024,829.94
152,850
33,379,940.7…
IRCProposed Rules (FR)Proposed Oct 14, 2016
…s after liquidation, but for entries filed on or after that date, it is now 180 days (
see
CFR part 174;
see19 U.S.C. 1514(c)(3) as amended by section 2103(2)(B), Pub. L. 108-429).
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6.
See 19 CFR 159.12.
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7.
Based on the 2,500 Applications for Further Review (AFRs) filed with protests…
IRCFinal Rules (FR)Dec 12, 2016
…s after liquidation, but for entries filed on or after that date, it is now 180 days (
see
CFR part 174;
see19 U.S.C. 1514(c)(3) as amended by section 2103(2)(B), Pub. L. 108-429).
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6.
See 19 CFR 159.12.
Back to Citation
7.
Based on the 2,500 Applications for Further Review (AFRs) filed with protests…
78 FR 53704 — Employee Retirement Benefit Plan Returns Required on Magnetic Media IRCProposed Rules (FR)Proposed Aug 30, 2013related by meaning
ublic hearing is scheduled, notice of the date, time, and place of the public hearing will be published in the
Federal Register
.
Drafting Information The principal authors of these regulations are William Gibbs and Pamela R. Kinard, Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities…
IRCCourt RulingsFeb 18, 1981
…wledge that the agreed fair market value of the Nodaway stock was $173,600 ($124 x 1,400), and not $174,270, the present value of the annuity. Nevertheless, for the remainder of this opinion, we will assume that the agreed fair market value of the Nodaway stock equaled the present value of the annuity, $174,270.
Rev. R…
Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 2, 2024
…g
172
.03 Closing agreement
173
.04 Determination letter
173
.05 Opinion letter
173
.06 Oral advice
174
.07 Nonbank trustee approval letters
174
.08 Compliance statement
175
.09 Advisory letter
175
SECTION 4. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS PROCEDURE?
175
.01 In general
175
.02 Determinat…