IRCCourt RulingsSep 30, 1991related by meaning
023.94
81,023.94
81,023.94
81,023.94
64,819.15
For taxable year ended November 26, 1986, respondent determined a second-tier deficiency of $6,481,915. The issues presented for our consideration all involve whether a sale of real estate by petitioners to an employee stock ownership plan was a prohibited transaction givi…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
79 FR 10296 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCFinal Rules (FR)Feb 24, 2014
…situated individual who enrolls in the same coverage when first eligible.
* * * * *
31. Section 146.119 is revised to read as follows:
§ 146.119
HMO affiliation period as an alternative to a preexisting condition exclusion.
The rules for HMO affiliation periods have been superseded by the prohibition on preexisting con…
IRCCourt RulingsJul 11, 2012related by meaning
ditional tax provided by section 72(t)), penalties, and statutory
interest.. See Katz v. Commissioner, 115 T.C. 329, 338-339 (2000). The record
. 12 - does not establish that petitioners received a.notice of deficiency for 2007 and
consequently a challenge to petitioners' 2007 tax liability is allowed in thi
judicial p…
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, 2013
…situated individual who enrolls in the same coverage when first eligible.
* * * * *
33. Section 146.119 is revised to read as follows:
§ 146.119
HMO affiliation period as an alternative to a preexisting condition exclusion.
The rules for HMO affiliation periods have been superseded by the prohibition on preexisting con…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
78 FR 39870 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Jul 2, 2013
….S.C. 1002(16), 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1185d, 1191, 1191a, 1191b, and 1191c; sec. 101(g), Public Law 104-191, 110 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 U.S.C. 651 note); sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1…
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
78 FR 8456 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 6, 2013
….S.C. 1002(16), 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1185d, 1191, 1191a, 1191b, and 1191c; sec. 101(g), Public Law 104-191, 110 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 U.S.C. 651 note); sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1…
IRCCourt RulingsSep 17, 2026related by meaning
n effect at all relevant times, regulation references are
to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure.
Served 09/17/26
2
[* 2 ] there were no changes in the IRS approach to the issue after review
of…
Rev. Rul. 2004-65 — Post-retirement health benefits; waiver. This ruling holds that an employer has reduced retiree health coverage, within the meaning of section 420(c)(2)(E) of … IRCRevenue RulingsJul 6, 2004related by meaning
INCOME TAX
Rev. Rul. 2004-63 Rev. Rul. 2004-63
Special use value; farms; interest rates. The 2004 interest rates to be used in computing the special use value of farm real property for which an election is made under section 2032A of the Code are listed for estates of decedents.
Rev. Rul. 2004-66 Rev. Rul. 2004-66
Fede…
75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient… IRCFinal Rules (FR)Jul 23, 2010
…urden imposed by this ICR will require five minutes of a legal professional's time (with a rate of $119.03/hour) to determine the relevant documents that must be retained and ten minutes of clerical staff time (with a labor rate of $26.14/hour) to organize and file the required documents to ensure that they are accessi…
IRCCourt RulingsNov 26, 2014related by meaning
ll the relevant facts and as to whether those facts are in
dispute.
June Waage (an officer), for petitioners.
Shawn P. Nowlan, for respondent.
OPINION BUCH, Judge: Petitioners are before the Court seeking declaratory
judgments as to the revocation of their retirement plans' qualified status under
section 401.1 After in…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…ocess from approximately $100.2 million, as specified in the 2023 proposed rules, to approximately $119.4 million in these final rules to reflect the costs of carrying out the Federal IDR process at the current volume of disputes and take into consideration the costs of implementing the provisions finalized in these fi…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsMay 27, 1968related by meaning
404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60.
All Code references herein are to the Internal Revenue Code of 1954.
Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
IRCCourt RulingsDec 23, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-556
UNITED STATES TAX COURT
ALFRED P. DUFFY, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respo…
IRCCourt RulingsJan 27, 1998related by meaning
e extent applicable," by the
regulations, rulings, opinions, and exemptions issued by the DOL
as provided in Reorganization Plan sections 102 and 105. In December 1991, the IRS notified the DOL about its intent
to disqualify the Plan. At this time, the DOL was pursuing ERISA
title I remedies against the Plan. In Februa…
U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner IRCCourt RulingsJun 26, 2018related by meaning
C T
T.C. Memo. 201 8-92
UNITED STATES TAX COURT
VAL LANES RECREATION CENTER CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24887-10R. Filed June 26, 2018.
James R. Monroe and Michael A. Gilmer, for petitioner.
Nicholas D. Doukas and David Conrad, for respondent.
MEMORANDUM FINDINGS O…
49 T.C. 174 — Armanco Productions, Inc. v. Commissioner IRCCourt RulingsDec 8, 1967related by meaning
t-sharing trust. Our conclusion makes it unnecessary to consider respondent’s alternative argument that the deduction should be limited to $10,346.69. Section 401(a) and the regulations pursuant thereto require that the plan not discriminate in favor of employees who are officers, shareholders, or highly compensated em…