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78 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 142 T.C. No. 21 — Whistleblower 11332-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    alth Care Act of 2006 (TRHCA)2, Pub. L. No. 109-432, div. A, sec. 406, 120 Stat. at 2958, effective December 20, 2006. We hold that we do.3 Background The following background is drawn from the petition and respondent's motion to dismiss for lack of subject matter jurisdiction and responses filed by both parties. We no…
  2. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    tinued...) - 5 - of the Secretary, and in the same manner as taxes. Sec. 6652(c) (4) (A). Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and demand, the Secretary can collect the tax by levy upon the property belonging to the person, subject to …
  3. 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…
  4. I.R.C. § 6662(d)(2)(B)(ii)(I) — Imposition of accuracy-related penalty on underpayments
    IRCCode / StatuteJan 5, 2023related by meaning
    (d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and (d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer. (d)(2)(C) (C) Reduction not to apply to tax shelters (d)(…
  5. 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 …
  6. 89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities
    IRCFinal Rules (FR)Apr 25, 2024related by meaning
    )(i), as contained in 26 CFR part 1, revised as of April 1, 2024. Douglas W. O'Donnell, Deputy Commissioner. Approved: April 2, 2024. Aviva Aron-Dine, Acting Assistant Secretary of the Treasury (Tax Policy). Footnotes 1.  PLR 200923001 (February 26, 2009). Back to Citation 2.   See also STAFF OF THE JOINT COMM. ON TAX'…
  7. 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…
  8. 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…
  9. 75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Jun 16, 2010related by meaning
    URE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * *. Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows: § 301.6404-0 Table of Contents. * * * * * § 301.6404-4 Suspension of interest and c…
  10. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    ccuracy-related penalty under section 6662. OPINION I. Preliminary Matters Petitioner argues that respondent bears the burden of proof with respect to his unreported income for both tax years. For the reasons below, we disagree. Generally, the Commissioner's determinations in a notice of deficiency are presumed correct…
  11. Treas. Reg. § 54.4975-7(a) — Other statutory exemptions.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) [Reserved]
  12. T.C. Memo. 2012-94 — Child Adult Intervention Services, Inc. v. Commissioner
    IRCCourt RulingsMar 28, 2012related by meaning
    ctive for determinations made after October 16, 2006, this Court has jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v. Commissioner, 130 T.C. 44, 48 & n.4 (2008). - 6 - Respondent does not dispute that petit…
  13. 89 FR 102735 — Disclosure of Records
    IRCFinal Rules (FR)Dec 18, 2024related by meaning
    Back to Citation 21.  31 CFR part 323. Back to Citation 22.  31 U.S.C. 3105(f)(1)(C). Back to Citation 23.  31 U.S.C. 3105(f)(2). Back to Citation 24.  5 U.S.C. 605(b). Back to Citation [FR Doc. 2024-29988 Filed 12-17-24; 8:45 am] BILLING CODE P
  14. 29 C.F.R. § 2570.6 — Consent order or settlement.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, the following shall apply in lieu of § 18.9 of this title.
  15. 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…
  16. Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o…
    IRCRevenue ProceduresOct 17, 2016related by meaning
    sing Form 8821, Tax Information Authorization. (See Form 8821 and Instructions) See section 10.09 for special rules relating to Anonymous Submissions. .08 Penalty of perjury statement. (1) The Plan Sponsor must sign the penalty of perjury statement on the Form 8950 as part of a VCP submission. In addition, the followin…
  17. 87 FR 52618 — Requirements Related to Surprise Billing
    IRCFinal Rules (FR)Aug 26, 2022
    …s Act.” U.S.C.-Brookings Schaeffer on Health Policy. (March 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 114.  2 U.S.C. 1501 et seq. (1995). Back to Citation 115.  See House Conf. Rep. No. 104-73…
  18. PLR 200737046 — Tax on Prohibited Transactions
    IRCPrivate Letter RulingsSep 14, 2007related by meaning
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