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60 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 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
    …1-2, and 2799B1-B2 of the PHS Act; section 1321(a)(1) and (c) of ACA; sections 7805, 9816-9817, and 9822 of the Code; and sections 2746, 2799A-1-2, and 2799B1-B2 of the PHS Act. 6.   See also64 FR 70164 (December 15, 1999). Back to Citation 7.
  2. Treas. Reg. § 54.9815-2719AT(c) — Patient protections (temporary).
    IRCRegulationsSep 13, 2021
    …ars beginning before January 1, 2022. See also §§ 54.9816-4T through 54.9816-7T, 54.9817-1T, and 54.9822-1T for rules applicable with respect to plan years beginning on or after January 1, 2022.
  3. Treas. Reg. § 54.9816-1T(a) — Basis and scope (temporary).
    IRCRegulationsOct 7, 2021
    (a) (a) Basis. This section and §§ 54.9816-2T through 54.9816-8T, 54.9817-1T, 54.9817-2T, and 54.9822-1T implement subchapter B of chapter 100 of the Internal Revenue Code of 1986.
  4. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    of (1) the amount contributed to an IRA for the taxable year (other than a “ rollover contribut io n ” described in section 408(d)(3) ) , over (2) the amount allowable as a deduction under section 219 for such contribution. § 4973(b)(1). This excise tax continues to apply to future tax years, until such time as the ori…
  5. 29 C.F.R. § 2570.34(f)(11)(i)(E) — Information to be included in every exemption application.
    ERISARegulationsApr 8, 2024related by meaning
    (f)(11)(i)(E) (E) Any felony or conspiracy involving the larceny, theft, robbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds or securities; or (f)(11)(ii) (ii) A statement describing the applicable investigation, examination, litigation,…
  6. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    ions, this Court concludes that a section 6673 penalty of $500 is appropriate. It is "inappropriate that taxpayers who promptly pay their taxes should have the cost of Government and tax collection improperly increased by citizens apparently unwilling to obey the law or shoulder their assigned share of the Government c…
  7. 141 T.C. No. 19 — Andrew Wayne Roberts v. Commissioner
    IRCCourt RulingsDec 30, 2013related by meaning
    the amount of tax imposed that is shown on the return, reduced by any rebate. Sec. 6662(d)(2)(A). The amount of the understatement is reduced by that portion of the understatement that is attributable to (1) the tax treatment of any item if there is or was substantial authority for such treatment, or (2) any item if t…
  8. T.C. Summary Opinion 2006-8 — Terry Fred Burnham v. Commissioner
    IRCCourt RulingsJan 26, 2006related by meaning
    ate are treated as payments not received as an annuity and are taxable. Sec. 72(e)(2)(A). There is simply not sufficient information in this record to reach a conclusion whether some portion of the $8,000 payment is not includable in income. The Court and respondent encouraged - 10 - petitioner to provide sufficient in…
  9. Joint BoardRegulationsDec 30, 2016related by meaning
    (d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved. (d)(4)(iv) (iv) Public i…
  10. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation 52.  5 U.S.C. 601 et seq. Back to Citation 53.  5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551. Back to Citation 54.  Public Law 104-4, 109 Stat. 48 (Ma…
  11. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    IRCCourt RulingsAug 27, 2018related by meaning
    0 and $5,379, respectively; and (4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014 of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a) penalties in writing by making an entry in the Correspondence Examination Automation Case Support…
  12. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    15 of the year following the taxable year, for which no deduction is allowed with respect to the contribution, are not taxable upon distribution. Sec. 408(d)(4); Childs v. Commissioner , T.C. Memo. 1996-267. Petitioner was employed by the Tribe in Indian fishingrights-related activity. Payments to petitioner for such I…
  13. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
  14. T.C. Memo. 1998-321 — Robert J. Hoaglund v. Commissioner
    IRCCourt RulingsSep 9, 1998related by meaning
    s and claims against a debtor's estate. Sec. 507(a)(8) of the Bankruptcy Code provides a priority for unsecured claims of governmental units for taxes measured by income or gross receipts within the time periods set forth therein. by respondent's motion for the reason explained below. However, because no justiciable is…
  15. I.R.C. § 6652(c)(4)(B) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(4)(B) (B) Managers The Secretary may make written demand on an organization subject to penalty under subparagraph (A) specifying in such demand a reasonable future date by which the notice shall be submitted for purposes of this subparagraph. If such notice is not submitted on or before such date, there shall be pa…
  16. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    e excise tax notwithstanding that they may have acted innocently or in good faith. Rutland v. Commissioner , 89 T.C. 1137, 1146 (1987). In signing the Agreement and Assignment of Accounts Receivable as a corporate officer, petitioner, along with Mr. Cohen, implemented the transfer of accounts receivable to the Plan. In…
  17. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    s less than the dollar amount accrued, the foreign tax credit for the year in question should be correspondingly adjusted. We hold for the respondent. Initially, we note that the Code encompasses a system of taxation in respect of income of United States persons and of income of non-United States persons from sources w…
  18. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    of eligible individuals, suspended it for 5 years for the vast majority of CSRS employees. The portion of sec. 72(e) involved herein reads as follows: SEC. 72(e). Amounts Not Received as Annuities.— (1) Application of subsection.— (A) In general. — This subsection shall apply to any amount which— (i) is received under …
  19. 119 T.C. No. 6 — Robert Ancira v. Commissioner
    IRCCourt RulingsSep 24, 2002related by meaning
    titioner is not liable for the sec. 6662 penalty. 3 S.K. apparently stands for Smoothie King, which we gather was the trade name of a product. OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 The Court agrees with and…
  20. I.R.C. § 6662(d)(2)(B)(ii)(I) — Imposition of accuracy-related penalty on underpayments
    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)(…