T.D. 9166 — Final regulations under section 9801 of the Code provide guidance on the Health Insurance Portability and Accountability Act of 1996 (HIPAA) portability requir… IRCTreasury DecisionsFeb 22, 2005
…ly prohibits the issuer from terminating or failing to offer to renew the insurance (see 45 CFR 146.152). With respect to very small employers, whether group health insurance is subject to the requirements of 45 CFR 146.152 is generally determined by whether the group health plan has two or more participants who are cu…
IRCCourt RulingsOct 25, 1961related by meaning
ctive argues strongly against the respondent’s position that there was an unexpressed intention to limit the N.E.C.’s powers with respect to partners. Respondent “admits that he is bound to carry out the purposes of Title IV of the Defense Production Act of 1950 * * * as set forth under Section 401 thereof.” We conclud…
IRCCourt RulingsOct 29, 2013related by meaning
s amount includes the additional tax of $32,137 under sec. 72(t).
- 27 -
[*27] that the determination of reasonable cause and good faith "is made on a case-by-case basis, taking into account all pertinent facts and circumstances." Sec.
1.6664-4(b)(1), Income Tax Regs.
The parties have agreed in the stipulation of settl…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
PBGCRegulationsJan 1, 2017
…nt age under the plan is $1,200 per month. The maximum guaranteeable benefit adjusted for age is $1,152.61 ($2,352.27 × 0.49) per month. A form adjustment is not required.Benefit reductions. The plan benefit of $1,800 per month payable from age 56 to age 62 exceeds the participant's accrued benefit at normal retirement…
IRCRegulationsDec 30, 2016
…lan or issuer limits dependent child coverage to children under age 26 who are described in section 152(f)(1) . For an individual not described in section 152(f)(1), such as a grandchild or niece, a plan may impose additional conditions on eligibility for dependent child health coverage, such as a condition that the in…
IRCCourt RulingsJul 13, 2010related by meaning
all of the contentions and arguments of
the parties that are not discussed herein, and we conclude that
they are without merit, irrelevant, or moot . "Para . 6 of the petition filed by each petitioner admits
:
"According to Section 6673, this court may penalize Petitioner up
to $25,000 for failure to complete the admin…
Notice 2025-68 — Notice of intent to issue regulations with respect to section 530A Trump accounts IRCNoticesDec 22, 2025
… who anticipates that the eligible child will be his or her qualifying child (as defined in section 152(c)) for purposes of section 6434 for the tax year in which the election is made. If an individual makes an election in anticipation that the eligible child will be the individual’s qualifying child under section 152(…
IRCCourt RulingsJun 9, 1977related by meaning
ring trust was valid and of full force and effect. Cf. Precision Industries, Inc. v. Commissioner, 64 T.C. at 907. Moreover, it is irrelevant that Mr. Crist did not reduce his acquiescence to a written form; such an irregularity does not invalidate the authorization in these circumstances. Armstrong Manors v. Burris, 1…
Notice 2003-73 — Retirement plans; year 2004 section 415(d) limitations. This notice sets forth certain cost-of-living adjustments effective January 1, 2004, applicable to the … IRCNoticesNov 10, 2003related by meaning
hing a resolution. At their discretion, they may allow information to be provided to them in a joint presentation by the taxpayer.
Resolution of cases While the staff of the respective competent authority offices will continue to carry on the primary negotiation of cases arising under Mutual Agreement Article of the Co…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
tment. Sec. 452 (b) (2); sec. 40.452-1, Regs. 130. Here, the petitioner has not maintained an inconsistent position within the meaning of section 452. It does not insist that the deduction for officers’ compensation in the fiscal year 1941 was improperly claimed. It does not maintain that any portion of such compensati…
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…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
for the 5-percent excise
tax on prohibited transactions under section 4975(a) for 1982 to
1993.
2. Whether petitioners are liable for additions to tax under section 6651(a)(1) for 1982 to 1993. We hold that they are
to the extent discussed below.
At trial, respondent conceded that petitioners are not
liable for the 100…
PLR 201930009 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJul 26, 2019
…of the
participant, the participant’s spouse, or the participant’s dependent (as defined by
section 152, without regard to section 152(b)(1), (b)(2) and (d)(1)(b);
(ii) Loss of property due to casualty; or (iii) Other similar extraordinary and
unforeseeable circumstances arising as a result of the events beyond the con…
PLR 201024011 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJun 18, 2010
…ess or accident of the participant or the
participants spouse or dependent s (as defined in section 152 of the Code without
regard to sections 152(b)(1), (b)(2), and (d)(1)(B)); (B) loss of the participant’s property
due to casualty; or (C) other similar extraordinary and unforeseeable circumstances
arising as a result…
IRCCourt RulingsJul 24, 2003related by meaning
1
Unless otherwise indicated, section references
hereafter are to the Internal Revenue Code in effect for the year
at issue.
T.C. Summary Opinion 2003-103
UNITED STATES TAX COURT
SANTOS M. AND INGRID I. CASTILLO, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4698-02S. Filed July 24, 2003.
Sant…
PLR 200727005 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJul 6, 2007
…of the participant, the participant’s spouse, or
the participant’s dependent (as defined by Section 152(a) of the Code), (b) the loss of
the participant’s property due to casualty (including the need to rebuild a home following
damage to a home not otherwise covered by insurance), (c) the need to pay for the
funeral ex…
IRCCourt RulingsMar 7, 2019
…loyee or as a director? See Jacobs, 1993 WL 495594,
at *2 (citing Rev. Rul. 82-83, 1982-1 C.B. 151, 152). Directorial services
typically include things like attending board meetings and sitting on committees,
while services performed by officers generally include the fundamental everyday
decisions about corporate opera…
IRCCourt RulingsFeb 12, 2003related by meaning
A Tax” for 1989. Respondent
conceded for Mr. Clendenen: (1) The increase to taxable income
of $92,712 for “Capital Gains and Losses” for 1988; (2) the addition to tax of $1,704 under sec. 6653(a)(1) for 1988; and (3)
the addition to tax of $237 under sec. 6662(a) for 1989.
Respondent and Mr. Clendenen agreed that this …
IRCCourt RulingsSep 24, 2026
…nnecting the taxpayer with the income -
pro ducing activity, see Llorente v. Commissioner, 649 F.2d 152, 156 (2d
Cir. 1981), aff’g in part, rev’g and remanding in part 74 T.C. 260 (1980),
or demonstrate that the taxpayer actually received income, Edwards v.
Commissioner, 680 F.2d 1268, 1270 – 71 (9th Cir. 1982) (per cu…