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56 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2007-306 — David Brian Nolan v. Commissioner
    IRCCourt RulingsOct 9, 2007related by meaning
    ers . In response to our leniency, petitioner once again ignored our Rules and our order . -5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a sanction pursuant to Rule 123(b) . See Stringer v . Commissioner , 84 T .C . 693, 704-705 (1985), affd . withou…
  2. 50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner
    IRCCourt RulingsMay 29, 1968related by meaning
    Fat, Judge: Respondent determined a deficiency of $19,124.01 in petitioner’s income tax for the taxable year 1960. Petitioner conceded all the issues raised in the pleadings except one. The issue left for decision is whether section 404(a) (5) prohibits petitioner from deducting in its taxable year 1960 the sum of $36,…
  3. U.S. Tax Court — John C. Armbrust v. Commissioner
    IRCCourt RulingsJan 19, 2010related by meaning
    JOHN C . . A MBRUST, Petitioner v . COMMISSTONEROF INTERNAL 'REVENUE, Responden t .° Filed .' January` "19, 2010 . GOLDBERG , Specia l Trial" Judge : ,' This case w as heard-pursuant to the provision ` s of secti n6 7463 of' .the Internal Revenue Code i n effect at the time the {pet'tion was filed . Pursuant ' to '-sec…
  4. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021related by meaning
    notice that a provider, facility, or provider of air ambulance services has initiated the Federal IDR process, upon sending or receiving such notice. (2) The Director will coordinate with the Departments in resolving matters under 26 CFR 54.9816-8T(c)(4)(vii)(A)( 1), 29 CFR 2590.716-8(c)(4)(vii)(A)( 1), or 45 CFR 149.…
  5. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    ded because he and his wife were induced to sign it through fraud or misrepresentation. As we explain below, though, this issue is not properly before the Court. See infra pt. I, pp. 39-40. Sixth, Goldberg argues that he is entitled to abatement of interest under section 6404(e)(1). As we explain below, this issue is p…
  6. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    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…
  7. T.C. Memo. 2010-115 — Ronald D. & Lorie A. Jelling v. Commissioner
    IRCCourt RulingsMay 27, 2010related by meaning
    rule or regulation . Sec . 1 .6662-3(b)(2), Income TaxRegs . Disregard of rules or regulations . is reckless if the taxpayer makes little or no effort to determine whether .a rule or regulation exists Id . Under section 7491(c), the Commissioner bears the burden of production with regard to penalties and must come forw…
  8. Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022
    IRCNoticesModified Jan 8, 2024
    …dual retirement annuity described in section 408(b). 6 The definition of “State” for purposes of 42 USC 1395x(r)(1) is in 42 USC 410(h), which provides that the term “State” includes the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa.
  9. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …& Dana P. Goldman, Overpaying for Prescription Drugs: The Copay Clawback, (2018), https://schaeffer.usc.edu/​research/​overpaying-for-prescription-drugs/​.) Back to Citation 183.  Megan Thompson (2018), W hy a Patient Paid a $285 Copay for a $40 Drug, https://www.pbs.org/​newshour/​health/​why-a-patient-paid-a-285-copa…
  10. T.C. Memo. 2000-391 — Robert C. Geib v. Commissioner
    IRCCourt RulingsDec 28, 2000related by meaning
    T.C. Memo. 2000-391 UNITED STATES TAX COURT ROBERT C. GEIB, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7109-98. Filed December 28, 2000. Robert C. Geib, pro se. Mark A. Ericson and Laurence D. Ziegler , for respondent. MEMORANDUM OPINION FOLEY, Judge : By notice dated January 15, 1998, respo…
  11. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    claimed medical transportation expenses and that he falls under the exception in section 72(t)(2)(B). As discussed supra Part II.A, petitioner is not entitled to deduct his claimed medical transportation expenses under section 213(a). Therefore, he does not fall under the exception in section 72(t)(2)(B) and he is lia…
  12. T.C. Memo. 2024-67 — Fabricio Moran v. Commissioner
    IRCCourt RulingsJun 17, 2024related by meaning
    eption set forth in section 72(t)(2) applies. We accordingly sustain the IRS’s determination of a $ 242 additional tax for 2018. III. Additions to Tax The IRS determined additions to tax under sections 6651(a)(1) and (2) and 6654. Petitioner did not assign error, in his Petition or in any other filing with the Court, t…
  13. 86 FR 66495 — Prescription Drug and Health Care Spending
    IRCProposed Rules (FR)Proposed Nov 23, 2021related by meaning
    DOL, and HHS. List of Subjects in 26 CFR Part 54 Excise taxes Pensions Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, 26 CFR part 54 is proposed to be amended as follows: PART 54—PENSION EXCISE TAXES Paragraph. 3. The authority citation for part 54 continues to read as foll…
  14. 78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Mar 21, 2013related by meaning
    amended. List of Subjects 26 CFR Part 54 Excise taxes Health care Health insurance Pensions Reporting and recordkeeping requirements 29 CFR Part 2590 Continuation coverage Disclosure Employee benefit plans Group health plans Health care Health insurance Medical child support Reporting and recordkeeping requirements 45…
  15. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    version is subject to the section 4980 'to the extent' Research Corporation has been subject to UBIT [unrelated business income tax], based upon - 6 - the proportion of UBTI received by Research Corporation.in comparison to its other income".2 Petitioner based its calculation that only $14,055 of the total reversion of…
  16. T.C. Memo. 2014-227 — Brian K. Brinkley v. Commissioner
    IRCCourt RulingsOct 30, 2014related by meaning
    T.C. Memo. 2014-227 UNITED STATES TAX COURT BRIAN K. BRINKLEY, Petitioner y. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7367-13. Filed October 30, 2014. William R. Leighton, for petitioner. Roberta L. Shumway, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge: Respondent determined a $36…