83 FR 614 — Definition of “Employer” Under Section 3(5) of ERISA-Association Health Plans ERISAProposed Rules (FR)Proposed Jan 5, 2018
…ERISA section 3(1), to the extent the plan provides medical care. ERISA
( printed page 618)
section 733(a); PHS Act section 2791.
See also26 CFR 54.9831-1(a); 29 CFR 2590.732(a); 45 CFR 146.145(a). “Group health insurance coverage” means, in connection with a group health plan, health insurance coverage offered in conn…
IRCCourt RulingsMay 29, 2002related by meaning
to the additional tax under
section 72(t) and distinguished Larotonda and Murillo on the
ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is
equally true of the distribution here.
- 5 -
To reflect the foregoing,
An appropriate order of
dismissal a…
83 FR 7437 — Short-Term, Limited-Duration Insurance IRCProposed Rules (FR)Proposed Feb 21, 2018
…(3)(vii), 29 CFR 2590.732(c)(3)(vii), and 45 CFR 146.145(b)(3)(vii).
Back to Citation
15. Sections 733(b)(4) of ERISA and 2791(b)(4) of the PHS Act provide that group health insurance coverage means “in connection with a group health plan, health insurance coverage offered in connection with such plan.” Sections 733(a…
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…
IRCProposed Rules (FR)Proposed Dec 23, 2014
…apply to excepted benefits. Excepted benefits are described in section 2791 of the PHS Act, section 733 of ERISA, and section 9832 of the Code. The parallel statutory provisions establish four categories of excepted benefits. The first category includes benefits that are generally not health coverage [10]
(such as auto…
68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner IRCCourt RulingsSep 12, 1977related by meaning
r, 68 T.C. 826 (1977).
In view of concessions made by the parties and our conclusions on the disputed issues,
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated.
Variances between this schedule and Form 4848 reflect persons …
81 FR 75316 — Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance IRCFinal Rules (FR)Oct 31, 2016
… as “excepted benefits.” Excepted benefits are described in section 2791(c) of the PHS Act, section 733(c) of ERISA, and section 9832(c) of the Code.
The parallel statutory provisions establish four categories of excepted benefits. The first category, under section 2791(c)(1) of the PHS Act, section 733(c)(1) of ERISA …
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
ioners filed their memorandum on February 12, 2014, and
(continued...)
- 63 -
As an exception to the general rule of section 1.61-22(b)(1), Income Tax Regs., an arrangement between an owner and a nonowner of a life insurance
contract is a split-dollar life insurance arrangement if it is either a compensatory
arrangemen…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
81 FR 38020 — Expatriate Health Plans, Expatriate Health Plan Issuers, and Qualified Expatriates; Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Dura… IRCProposed Rules (FR)Proposed Jun 10, 2016
…xcepted benefits.” These excepted benefits are described in section 2791(c) of the PHS Act, section 733(c) of ERISA, and section 9832(c) of the Code. There are four statutorily enumerated categories of excepted benefits. One category, under section 2791(c)(1) of the PHS Act, section 733(c)(1) of ERISA, and section 9832…
IRCFinal Rules (FR)Mar 18, 2015
…apply to excepted benefits. Excepted benefits are described in section 2791 of the PHS Act, section 733 of ERISA, and section 9832 of the Code. The parallel statutory provisions establish four categories of excepted benefits. The first category includes benefits that are generally not health coverage [10]
(such as auto…
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…s To Participants and Beneficiaries:
Upon Application or Eligibility
2,030,000
1,015,000
16,917
500,733
16,917
500,733
Upon Renewal
58,000,000
35,960,000
599,333
17,740,267
599,333
17,740,267
Beneficiaries Living Apart
90,000
90,000
1,500
44,400
1,500
44,400
Sub-total
60,120,000
36,975,000
IRCCourt RulingsSep 14, 1993
…orm Act of 1986, Pub. L. 99-514, sec. 1122(h)(5), 100 Stat. 2085, 2471.
See H. Rept. 99-426, at 732-733 (1985), 1986-3 C.B. (Vol. 2) 1, 732-733; S. Rept. 99-313, at 608-609 (1986), 1986-3 C.B. (Vol. 3) 1, 608-609; H. Conf. Rept. 99-841 (Vol. II), at 459-462 (1986), 1986-3 C.B. (Vol. 4) 1, 459-462.
Prior to the 1986 leg…
IRCCourt RulingsMar 11, 2020related by meaning
little more than guesswork and failed to satisfy the strict substantiation
requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan
v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section
274(d). Cons…
IRCRegulationsSep 17, 2024
…385,115 381,339 19,462 365,653 2032 819,740 372,966 369,310 19,765 353,201 2033 775,430 360,265 356,733 19,955 340,310 2034 731,620 347,116 343,713 20,257 326,859 Table 5 to Paragraph (m)(4)(ii)(A) Year Survivorshipto startof year Interestdiscountto endof 2028 Mortalityrate duringyear Discountedadditionalbenefitswithin…
IRCCourt RulingsApr 2, 2024related by meaning
, 1485 (2021)
(“ [A]s this Court has long made plain, pleas of administrative
inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105,
2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is
clear, that is the…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
IRCCourt RulingsOct 1, 2015related by meaning
ioner, 106 T.C. 337, 340 (1996) (citing and discussing the legislative
history underlying section 408(f), the statutory predecessor to section 72(t)); Milner v. Commissioner, T.C. Memo. 2004-111.
Section 72(t)(2)(B) provides an exception to the imposition of additional tax
to the extent that retirement plan distributio…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
29 C.F.R. § 2520.104b-3(d) — Summary of material modifications to the plan and changes in the information required to be included in the summary plan description. ERISARegulationsJan 1, 2017
…n paragraph (d)(2) of this section, the administrator of a group health plan, as defined in section 733(a)(1) of the Act, shall furnish to each participant covered under the plan a summary, written in a manner calculated to be understood by the average plan participant, of any modification to the plan or change in the …