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82 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. IRCCourt RulingsOct 12, 1978related by meaning
    do not deal with the operations of the plan, there is a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comm…
  2. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …t forth in the preamble, the Department of Health and Human Services proposes to amend 45 CFR parts 147 and 158 as set forth below: PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS 5. The authority citation for part 147 continues to read as follows: Authority: 42 U.S.C…
  3. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    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…
  4. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975related by meaning
    d not the other facilities as it did here; and again supervision and control of the employees was exercised by the professional corporation. Rev. Rui. 75-41 was concerned with whether the individuals were employees of the service corporation for employment tax purposes, while here the issue is whether the individuals a…
  5. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984related by meaning
    rectly involved in such ruling. * * *” See also Rev. Proc. 67-1, 1967-1 C.B. 544; Rev. Proc. 72-3, 1972-1 C.B. 698; Rev. Proc. 80-24, 1980-1 C.B. 658. See Judge Chabot’s dissenting opinion in Woodson v. Commissioner, 73 T.C. 779,786,791 (1980), where it was suggested that the majority opinion therein could possibly be …
  6. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984related by meaning
    eived. An exception is provided in § 402(a)(2) for capital gains treatment in specific cases. * * * The exception was always strictly construed. * * * Further expansion of the favored treatment specifically provided in § 402(a)(2) as an exercise of legislative grace is a function for the Congress, not for the Courts. S…
  7. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    or was the filing fee paid. See Rule 173(a). The Court ordered petitioners to file a proper amended petition and pay the filing fee by May 2, 2003. 13 Petitioners timely filed an amended petition with the Court and paid the filing fee. In the amended petition, petitioners disputed deficiencies determined for taxable ye…
  8. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner. Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
  9. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001related by meaning
    claim to a pension plan contribution deduction on that ground forecloses her claim that she is entitled to an above-the-line Schedule C deduction for legal fees, rather than the itemized deduction subject to the 2percent limitation of section 67 that respondent allowed in the statutory notice. To give effect to all the…
  10. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    …iams v. Commissioner , 114 T.C. 136, 140 (2000). 5 See, e.g., Sloan v. Commissioner , 102 T.C. 137, 147 (1994) , affd. 53 F.3d 799 (7th Cir. 1995); Hintenberger v. Commissioner , T.C. Memo. 1990-36, affd. without published opinion 922 F.2d 848 (11th Cir. 1990); Britt v. Commissioner , T.C. Memo. 1988-419. 6 See, e.g., …
  11. 79 FR 51092 — Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Aug 27, 2014
    … the reasons stated in the preamble, the Department of Health and Human Services amends 45 CFR part 147 as follows: PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS 9. The authority citation for part 147 continues to read as follows: Authority: Secs 2701 through 2763, …
  12. 95 T.C. 415; 95 T.C. No. 30 — Albertson's, Inc. v. Commissioner
    IRCCourt RulingsOct 9, 1990related by meaning
    o. v. Commissioner, 30 T.C. 10, 22-23 (1958), affd. 267 F.2d 853 (7th Cir. 1959); Times Publishing Co. v. Commissioner, 13 T.C. 329, 335 (1949), affd. per curiam 184 F.2d 376 (3d Cir. 1950). Section 23(p) was reenacted as section 404 in the 1954 Code in essentially the same form. Don E. Williams Co. v. Commissioner, 42…
  13. 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
    …in paragraph (e)(3), including the paragraph heading, and adding in its place “2724”. 6. A new Part 147 is added to read as follows: PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS Authority: Secs 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 …
  14. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    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…
  15. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
    IRCProposed Rules (FR)Proposed Dec 30, 2014
    …s stated in the preamble, the Department of Health and Human Services proposes to amend 45 CFR part 147 as follows: PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS 1. The authority citation for part 147 continues to read as follows: Authority: Sections 2701 through 27…
  16. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related 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. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTE…
  17. 75 FR 70114 — Amendment to the Interim Final Rules for Group Health Plans and Health Insurance Coverage Relating to Status as a Grandfathered Health Plan Under the Patient P…
    IRCFinal Rules (FR)Nov 17, 2010
    …is paragraph (g). Department of Health and Human Services 45 CFR Chapter I Accordingly, 45 CFR part 147 is amended as follows: PART 147—HEALTH INSURANCE REFORM REQUIREMENTS FOR THE GROUP AND INDIVIDUAL HEALTH INSURANCE MARKETS 1. The authority citation for part 147 continues to read as follows: Authority: Secs. 2701 th…
  18. T.C. Memo. 1996-404 — Leonard A. Gross v. Commissioner
    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…
  19. Treas. Reg. § 54.9815-2713A(a) — Accommodations in connection with coverage of preventive health services.
    IRCRegulationsJan 14, 2019
    …through (4) of this section. (a)(1) (1) The organization is an objecting entity described in 45 CFR 147.132(a)(1)(i) or (ii), or 45 CFR 147.133(a)(1)(i) or (ii); (a)(2) (2) Notwithstanding its status under paragraph (a)(1) of this section and under 45 CFR 147.132(a) or 147.133(a), the organization voluntarily seeks to …
  20. 71 T.C. 824; 1 Employee Benefits Cas. (BNA) 2016 — Tamko Asphalt Products, Inc. v. Commissioner
    IRCCourt RulingsFeb 15, 1979related by meaning
    loyees, which have less generous plans or no plans at all, this would generally constitute an impermissable discrimination. * * * [Emphasis supplied.] We believe that a fair reading of section 414(b) would have alerted petitioner to the fact that such section requires, inter alia, that an affiliated group- comprised of…