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99 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  2. 89 FR 85750 — Enhancing Coverage of Preventive Services Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Oct 28, 2024
    …gulating a plan as an insurance or investment company or bank, the preemption provisions of section 731 of ERISA and section 2724 of the PHS Act (implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a)) apply so that the ACA's preventive service requirements are not to be “construed to supersede any provision of State …
  3. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005related by meaning
    Commissioner , 83 T.C. 755, 791 n.28 (1984); Kahler v. Commissioner , 18 T.C. 31, 34-35 (1952); Roberts v. Commissioner , T.C. Memo. 2002-281. In the instant case, the record reflects that the original check was not subject to substantial limitations, and petitioner makes no contention otherwise. Consequently, we find…
  4. 89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
    IRCFinal Rules (FR)Apr 3, 2024
    …ee benefit plan as an insurance or investment company or bank, the preemption provisions of section 731 of ERISA and sections 2724 and 2762 of the PHS Act (implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a) and 148.210(b)) apply so that the Federal consumer protections and requirements for comprehensive coverage a…
  5. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    articipants, Harold Breslow and Robert Levine, received their full benefit and petitioner signed an irrevocable waiver of his rights to Plan benefits. We reject petitioner's argument. Examining the record, we find no documentary evidence that all rank and file employees were paid their full vested interest, especially …
  6. 76 FR 37208 — Group Health Plans and Health Insurance Issuers: Rules Relating to Internal Claims and Appeals and External Review Processes
    IRCFinal Rules (FR)Jun 24, 2011
    …gulating a plan as an insurance or investment company or bank, the preemption provisions of section 731 of ERISA and section 2724 of the PHS Act (implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a)) apply so that the HIPAA requirements (including those of the Affordable Care Act) are not to be “construed to superse…
  7. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
  8. 76 FR 46621 — Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable Care Act
    IRCFinal Rules (FR)Aug 3, 2011
    …anges to which are incorporated into ERISA section 715). The preemption provisions of ERISA section 731 and PHS Act section 2724 [2] (implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a)) apply so that the requirements of part 7 of ERISA and title XXVII of the PHS Act, as amended by the Affordable Care Act, are not …
  9. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999related by meaning
    cise Tax Regs. Mr. Medina's assignment to the plan of future sales proceeds did - 8 - not result in the repayment of principal or interest. Therefore, petitioners did not correct the prohibited transaction, and the taxable period ended on June 25, 1997, the date respondent mailed the notice of deficiency. Accordingly, …
  10. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  11. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
    IRCCourt RulingsJul 25, 1974related by meaning
    ew principal place of work. Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217. SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
  12. T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov…
    IRCTreasury DecisionsAug 15, 2016related by meaning
    s in order to comply with their FATCA obligations, unless the FFIs qualify for an exemption under the FATCA regulations. Notice 2016–48 Notice 2016–48 This Notice explains how the IRS will implement the changes to the Individual Taxpayer Identification Number (ITIN) program resulting from the enactment of the Protectin…
  13. Rev. Rul. 2005-72 — 2006 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2006 are provided for use in …
    IRCRevenue RulingsNov 14, 2005related by meaning
    Form W-4, Employee's Withholding Allowance Certificate. The rules are effective with respect to wages paid on or after January 1, 2006. Notice 2005-85 2006 social security contribution and benefit base; domestic employee coverage threshold. The Commissioner of the Social Security Administration has announced (1) the OA…
  14. 31 T.C. 1022 — Judkins v. Commissioner
    IRCCourt RulingsFeb 25, 1959related by meaning
    ration from the service” within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners. In Mary Miller, 22 T.C. 293, affd. 226 F. 2d 618, the May Company acquired all the assets of the Strouss-Hirshberg Company in exchange for May Company stock. Three days …
  15. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …st year is estimated as: [(5,250 small entities × 10 hours) + (229 small entities × 20 hours) + (12,731 small entities × 5 hours)] ≉ 120,785 hours. A labor rate of $165.71 is used for a legal professional. The labor rate is used in the following calculation: [(5,250 small entities × 10 hours) + (229 small entities × 20…
  16. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  17. 75 FR 27122 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Dependent Coverage of Children to Age 26 Under the Patient Protection and A…
    IRCFinal Rules (FR)May 13, 2010
    …anges to which are incorporated into ERISA section 715). The preemption provisions of ERISA section 731 and PHS Act section 2724 [2] (implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a)) apply so that the requirements of the Affordable Care Act are not to be “construed to supersede any provision of State law which …
  18. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    …923 10,084,732 Accounts with AP 620,611 702,996 776,020 825,936 851,264 876,840 902,662 915,665 928,731 928,731 8,329,456 AP Transfers 397,749 519,606 630,585 699,159 724,418 766,494 809,360 817,864 839,779 824,156 7,029,170 Differences between the Baseline and Post-Rule: Default IRAs 144,664 166,262 184,775 197,117 20…
  19. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998related by meaning
    titioner, WE 7, and - 18 - 4 The complaint filed in the Superior Court indicates that the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987. the Guardian Construction Co., Inc., as corporate partners of Estes Co. Petitioner was identified as a partner…
  20. 75 FR 5410 — Interim Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008
    IRCFinal Rules (FR)Feb 2, 2010
    …ore restrictive than the requirements of MHPAEA are preempted. The preemption provisions of section 731 of ERISA and section 2723 of the PHS Act (added by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and implemented in 29 CFR 2590.731(a) and 45 CFR 146.143(a)) apply so that the MHPAEA require…