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61. 82 FR 47792 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Oct 13, 2017
    …contraceptive services: 14 of 18 FDA-approved women's contraceptive and sterilization methods.[68] (134 S. Ct. at 2766.) The effect of expanding the exemption to for-profit entities is therefore mitigated to the extent many of the persons covered by such entities' plans may receive coverage for at least some contracept…
62. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    ent with the intent of DEFRA, and because it permissibly fills a gap created by sections 419 and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is not impermissibly broader than sections 419 and 419A and, accordingly, we hold that it is valid. Chevron…
63. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    …olumn. Paragraph Remove Add § 726.302(c)(2)(i) August 1, 2016 January 13, 2017. § 726.302(c)(2)(i) $134 $136. § 726.302(c)(2)(i) 268 272. § 726.302(c)(2)(i) 402 409. § 726.302(c)(2)(i) 535 544. § 726.302(c)(4) August 1, 2016 January 13, 2017. § 726.302(c)(4) $134
64. Treas. Reg. § 1.410(b)-1 — [Reserved]
    IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
65. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
66. PLR 201440027 — Discrimination as to Contributions or Benefits (See Also 401.29-01,401.20-00,414.00-00)
    IRCPrivate Letter RulingsOct 3, 2014related by meaning
    te a contribution or other payment subject to the provisions of either section 404 or 4972 of the Code; will not adversely affect the qualified status of Plan C pursuant to either section 401 (a)(4) or 415 of the Code; and will not, when made, result in taxable income to affected Plan C participants or beneficiaries un…
67. T.C. Memo. 2012-44 — James Anthony Fonteneaux, Sr. v. Commissioner
    IRCCourt RulingsFeb 21, 2012related by meaning
    Respondent prepared decisiori.documents reflecting respolident's concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and . sanctions against respondent based on "reckless professional behavior." Petitioner is frustr…
68. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …ital Prices and Health Spending on the Privately Insured.” The Quarterly Journal of Economics, Vol. 134. Issue 1. February 2019. September 4, 2018. Available at: https://academic.oup.com/​qje/​article/​134/​1/​51/​5090426?​searchresult=​1. Back to Citation 22.   See Office of the Assistant Secretary for Planning and Ev…
69. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    d not make any estimated tax payments, but claimed that an exception applied. Petitioner did not specify the exception that purportedly applies - 15 - at trial or on brief and has failed to propose any findings of fact that would lead to the conclusion that any of the exceptions found in section 6654(e) applies to peti…
70. 85 FR 42782 — Grandfathered Group Health Plans and Grandfathered Group Health Insurance Coverage
    IRCProposed Rules (FR)Proposed Jul 15, 2020
    plans offered by private employers that cover an estimated 134.7 million participants and beneficiaries in those private employer-sponsored plans.[17] Similarly, the Departments estimate that there are 83,500 state and local governments that offer health coverage to their employees, with an estimated 42.8 million parti…
71. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
72. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    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…
73. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
74. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    general tax credit (sec. 42), which apparently was taken into account by respondent in his assertion of an increased deficiency and additions to tax. Respondent concedes that, if the 32-page document filed by petitioners with respondent for 1977 constitutes an income tax return for purposes of sec. 6651(a), then the r…
75. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    2, 513, and 514.—See section 3.01(78), above. (83) Section 529.—Qualified Tuition Programs.—Whether a state-run tuition program qualifies under § 529. (84) Sections 542, 543, and 544.—Definition of Personal Holding Company; Personal Holding Company Income; Rules for Determining Stock Ownership.—Whether the application …
76. 82 FR 60308 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 20, 2017
    …rity citation for part 4044 continues to read as follows: Authority: 29 U.S.C. 1301(a), 1302(b)(3), 1341, 1344, 1362. 2. Appendix D to part 4044 is amended by removing Table I-17 and adding in its place Table I-18 to read as follows: Appendix D to Part 4044—Tables Used To Determine Expected Retirement Age ( printed pag…
77. Treas. Reg. § 1.411(a)-4T(b) — Forfeitures, suspensions, etc. (temporary).
    IRCRegulationsSep 9, 2016related by meaning
    (b) (b) [Reserved]
78. T.C. Summary Opinion 2002-33 — Wallace F. & Mi-Ja H. Smith v. Commissioner
    IRCCourt RulingsApr 3, 2002related by meaning
    chedule A of a taxpayer's return. The measure of a casualty or theft loss is determined by section 1.165-7(b)(1), Income Tax Regs. Generally, the loss shall be the lesser of (1) the fair market value of the property immediately before the casualty reduced by the fair market value of the property immediately after the c…
79. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and (continued...) T.C. Memo. 1996-272 UNITED STATES TAX COURT TOMMY L. AND PATRICIA A. HOBSON, Petitioners v . COMMISSIONER OF INTERNAL R…
80. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983related by meaning
    …on. In the light of all the facts, we think respondent has the better side of the argument. Section 1348(a), in the form in which it was in effect in 1978, prescribed a 50-percent maximum tax rate limitation with respect to "personal service taxable income.” Section 1348(b)(1)(A) defined the term "personal service inco…