IRCCourt RulingsOct 6, 1988related by meaning
e the maximum amount of property qualifying for the marital deduction allowable by Federal law” within the meaning of section 403(e)(3)(B) of the act. In our view, clause 4 is precisely the type of provision that the transitional rule of ERTA was intended to encompass and, therefore, respondent’s position in this case …
Treas. Reg. § 54.9802-4(f)(1)(xii) — Special Rule Allowing Integration of Health Reimbursement Arrangements (HRAs) and Other Account-Based Group Health Plans with Individual Health Insurance Cover… IRCRegulationsAug 19, 2019
…ch of its 14 hourly employees an HRA on the same terms. Plan Sponsor J reasonably expects to employ 177 employees on the first day of the HRA plan year.
IRCCourt RulingsFeb 18, 1997related by meaning
, however, may not exceed
the lesser of $2,000 or an amount equal to the compensation
includable in the taxpayer's gross income for such taxable year. In addition, the amount of the deduction is limited where the
taxpayer was, for any part of the taxable year, an "active
participant" in a retirement plan qualified unde…
IRCProposed Rules (FR)Proposed May 13, 2026
…continuing collections of information in accordance with the Paperwork Reduction Act of 1995 (PRA).[177]
This helps to ensure that the public understands HHS's collection instructions, respondents can provide the requested data in the desired format, reporting burden (time and financial resources) is minimized, collect…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…k to Citation
96.
Id.
Back to Citation
97.
Table 1A, page 5 (stating that in coverage year 2015, 177.5 million persons of all ages were covered by employer sponsored insurance, with 135.7 million of those being covered by private sector employers), available at
https://www.dol.gov/sites/default/files/ebsa/resea…
IRCCourt RulingsAug 10, 2015related by meaning
mmissioner, 131 T.C. 185 (2008), supplementing T.C. Memo.
2007-340; Cyman v. Commissioner, T.C. Memo. 2009-144.
- 12 -
II. Section 1839
A. General Law Generally, the Internal Revenue Code allows deductions for ordinary and
necessary expenses incurred in conducting a trade or business or for the
production of income. Se…
IRCCourt RulingsApr 26, 1983
s from finding a gift where property worth $371,875 is exchanged for an annuity worth $177,500.92. See Estate of Bell v. Commissioner, 60 T.C. at 473. We also note that Marion did not seek to ascertain the cost of comparable commercial annuities before entering into the annuity agreement, a factor we have found to indi…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
… of State lawsuits that stem from allegations of deceptive practices resulting in financial losses.[177]
For example, in 2018, the Ohio Office of Attorney General reported that Centene Corporation, which oversaw Ohio's Department of Medicaid prescription drug program, had engaged in spread pricing which cost the State …
IRCCourt RulingsNov 13, 1998related by meaning
does not assert that any statutory
- 5 -
2
(...continued)
periodic payments (not less frequently than
annually) made for the life (or life expectancy) of the employee or joint lives (or joint life
expectancies) of such employee and his designated
beneficiary, or
(v) made to an employee after separation from
service aft…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…estimate that these proposed rules would affect 90,900 non-Federal governmental group health plans.[177]
Of these plans, approximately 35.7 percent [178]
(or 32,400) are self-insured,[179]
and 64.3 percent (or 58,400) are fully funded.[180]
2. Participants, Beneficiaries, and Enrollees
The Departments estimate that the…
Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru… IRCRevenue ProceduresJan 2, 2020
…3 Areas in which determination letters will not be issued
176
.04 Determination letter applications
177
.05 Review of determination letters
177
SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER?
178
.01 Scope of this section
178
.02 Scope of determination letters
178
.03 Design-based safe harbor
178
.04 Go…
IRCCourt RulingsJun 11, 1996related by meaning
rary purpose has been shown here.
Because we are satisfied that our analysis of section
4980A(e)(2) leads to the conclusion that the Retirement System was a qualified employer plan under section 4980A, we sustain
respondent's determination that petitioner is liable for the 15percent excise tax under section 4980A.
- 11…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ies agreed to an average price of $656,000 per finished lot and
estimated lot-finishing co st s of $177,000 per lot. On the b as is of these
terms, Mr. Duvall inferred a tract value of approximately $3.35 million
after accounting for the parties’ cost estimates. In another portion of
IRCCourt RulingsAug 8, 2005related by meaning
the employee or the joint
lives (or joint life expectancies) of such
employee and his designated beneficiary,
(v) made to an employee after separation from service after attainment of age 55,
(vi) dividends paid with respect to
stock of a corporation which are described in
section 404(k), or
(vii) made on account of a …
IRCRegulationsJul 26, 2016
…the investment in the contract of $25,000, results in an adjusted investment in the contract of $23,177.50. If A dies before receiving payments for 15 years and the remaining payments are made to B, his beneficiary, B shall exclude the entire amount of such payments from his gross income until the amounts so received b…
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
IRCCourt RulingsJan 3, 2011related by meaning
10 percent of the tax
required to be shown on the return for the taxable year or
$5, 000. Sec. 6662 (d) (1) (A) . An understatement" is the excess of the amount required to, be shown on the return for the taxable
year over the amount actually shown on the return. Sec.
66623(d) (2) .
The record reveals that petitioner' …