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78 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017related by meaning
    JRN T.C. Memo. 2017-112 UNITED STATES TAX COURT WHISTLEBLOWER 19860-15W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19860-15W. Filed June 13, 2017. Sealed,¹ for petitioner. Ashley M. Bender and Richard L. Hatfield, for respondent. MEMORANDUM OPINION KERRIGAN, Judge: This case is before the Co…
  2. PBGC Op. Ltr. 1994-8 — Withdrawal liability
    PBGCPBGC Opinion LettersSep 30, 1994
    …( 4)( B)> 421 9 N otice & Co llection o f W ithdraw al Liab ility 422 1 Reso lution of Disputes >29 USC 1461 n ote > OP INI ON : I wri te i n res ponse t o your reque st for the opini on of the Pension Benefit Guaranty Corporation ("PBG C"). Your fir st r equest c oncerns a par ticu lar applicat ion of t he princ iples…
  3. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    e Tax Court (and the Tax Court shall have jurisdiction) to determine the appropriate relief available to the individual under this section * * * - 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4 This amendment applies "with respect to liability for taxes arising or remaining unpaid on or after …
  4. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025related by meaning
    Memo. 2002-18, 83 T.C.M. (CCH) 1107 , 1108– 10 (imposing penalty of $2,000 under section 6673(a)), af f’ d , 54 F. App ’ x 254 (9th Cir. 2002) ; s ee G reat - West Life Assurance Co. v. United States , 678 F.2d 180, 183 ( Ct. Cl. 1982) (“The determination of where income is derived or ‘sourced’ is generally of no mome…
  5. 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
    …ing Department of Labor claims procedure regulation. That is, the Department of Labor interprets 29 USC 1133 and the DOL claims procedure regulation as already requiring that plans provide claimants with new or additional evidence or rationales upon request and an opportunity to respond in certain circumstances. See Br…
  6. 75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections
    IRCFinal Rules (FR)Jun 28, 2010
    … read as follows: Authority: 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended. 5. Add § 147.108 to read as follows: § 147.108 Prohibition of preexisting condition exclusions. (a) No preexisting condition exclusions —(1) In general. A …
  7. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  8. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    …the No Surprises Act. U.S.C.-Brookings Schaeffer on Health Policy. https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 340.   See, for example, the proposed 2027 HHS notice of benefit and payment parameters (9…
  9. I.R.C. § 501(c)(18)(D)(iv) — Exemption from tax on corporations, certain trusts, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(18)(D)(iv) (iv) the requirements of section 401(a)(30) are met. (c)(19) (19) A post or organization of past or present members of the Armed Forces of the United States, or an auxiliary unit or society of, or a trust or foundation for, any such post or organization— [(20) Repealed. Pub. L. 113–295, div. A, title II,…
  10. T.C. Summary Opinion 2006-8 — Terry Fred Burnham v. Commissioner
    IRCCourt RulingsJan 26, 2006related by meaning
    ate are treated as payments not received as an annuity and are taxable. Sec. 72(e)(2)(A). There is simply not sufficient information in this record to reach a conclusion whether some portion of the $8,000 payment is not includable in income. The Court and respondent encouraged - 10 - petitioner to provide sufficient in…
  11. PLR 201506015 — Roth IRA
    IRCPrivate Letter RulingsFeb 6, 2015related by meaning
    ternal Revenue Bulletin for the making of an election or application for relief in respect of tax under, among others, Subtitle A of the Code. Section 301.9100-2 of the Regulations lists certain elections for which automatic extensions of time to file are granted. Section 301.9100-3 generally provides guidance with res…
  12. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    it at petitioners’ table and was permitted to assist his father in the presentation of his father’s testimony. OPINION Taxation of Disability Payments Section 72(a) provides that gross income includes amounts received as an annuity. Section 72(d) provides that in the case of an annuity where part of the consideration i…
  13. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    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…
  14. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    IRCCourt RulingsMar 22, 2007related by meaning
    ddition to tax must be sustained. Section 6673(a)(1) authorizes the Court to require a taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or groundless or the taxpayer has instituted or pursued the proceeding primarily for delay. Respondent has n…
  15. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  16. T.C. Memo. 2000-78 — Philip Lewis Hart v. Commissioner
    IRCCourt RulingsMar 7, 2000related by meaning
    rental income, and IRA distributions are included in gross income and subject to Federal income tax. Secs. 1, 61(a)(4), 61(a)(5), 61(a)(9), 61(a)(11), 408(d). Petitioner's income from wages, interest, rent, and IRA distributions is taxable. We sustain respondent's determinations on these issues. We next consider whethe…
  17. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …the No Surprises Act. U.S.C.-Brookings Schaeffer on Health Policy. https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 262.  See Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Cert…
  18. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006related by meaning
    yments to insure the maximum amount of assessed tax is collected, and courts have allowed reallocation of funds in light of new information or changed circumstances in situations where the taxpayer has made no showing o f injury from the reallocation. Davis v. United States , 961 F.2d 867, 878-9 (9 th Cir.1992). “Strai…