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61. 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…
62. 89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities
    IRCFinal Rules (FR)Apr 25, 2024related by meaning
    not impose substantial direct compliance costs on State and local governments, and do not preempt State law within the meaning of the Executive order. Statement of Availability of IRS Documents IRS Revenue Procedures, Revenue Rulings, Notices, and other guidance cited in this document are published in the Internal Reve…
63. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015related by meaning
    n October 13, 2011, petitioner's wife sent a final letter to Settlement Officer Owyhng informing him that petitioner had received his October 6, 2011, letter, and that petitioner had requested an extension of time on September 26, -7- [*7] 2011. The letter also reiterated that petitioner had no access to a computer and…
64. Circular 230 § 10.72(d)(4)(iii) — Hearings.
    Joint BoardRegulationsDec 30, 2016related by meaning
    (d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved. (d)(4)(iv) (iv) Public i…
65. 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…
66. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    foregoing quoted terms are specially defined and used under the "Public Salary Tax Act of 1939" ; 3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor "taxpayer," nor "non-resident alien," nor any other "legal entity" "made liable for" or "subject to" any "internal reve…
67. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
68. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962. To…
69. 88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCFinal Rules (FR)Feb 23, 2023related by meaning
    7805 * * * * * * * * Section 1.6033-4 also issued under 26 U.S.C. 6033. * * * * * Section 1.6037-2 also issued under 26 U.S.C. 6037. * * * * * Par. 2. Section 1.1461-1 is amended by removing paragraph (c)(5); redesignating paragraph (i) as paragraph (j); adding a new paragraph (i); and revising newly redesignated parag…
70. 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…
71. 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…
72. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008related by meaning
    ven such regulations is well known. See, e.g., Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837 (1984); Swallows Holdino, Ltd. v. Commissioner, 515 F.3d 162 (3d Cir. 2008), vacating 126 T.C. 96 (2006). The delegation Congress made to the Secretary in section 404(k)(5) (A), however, is particularly …
73. 88 FR 76660 — Technical Amendments: Special Financial Assistance Withdrawal Liability Condition; SECURE 2.0 Act; and Other Updates
    PBGCFinal Rules (FR)Nov 7, 2023related by meaning
    a speech disability, please dial 7-1-1 to access telecommunications relay services”. § 4000.28 [Removed and Reserved] 3. Remove and reserve § 4000.28. PART 4003—RULES FOR ADMINISTRATIVE REVIEW OF AGENCY DECISIONS 4. The authority citation for part 4003 continues to read as follows: Authority: 29 U.S.C. 1302(b)(3). § 40…
74. Notice 2026-9 — This notice provides guidance relating to amendments under section 501 of the SECURE 2.0 Act of 2022 for individual retirement arrangements and annuities (IRAs…
    IRCNoticesFeb 9, 2026related by meaning
    igibility to represent taxpayers before the IRS in examinations of tax returns the preparer both prepared for the taxpayer and signed as the preparer. Additionally, unenrolled/unlicensed return preparers who participate in the AFSP agree to be subject to the duties and restrictions in Circular 230, including the restri…
75. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    Tax, Additional Amounts, and Assessable Penalties".¹° What these terms have in common is that they refer to amounts that are assessed 8(...continued) 23, 1998, see Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105-206, sec. 3001(c), 112 Stat. at 727, and the taxpayer in that case anyway bo…
76. I.R.C. § 6652(c)(4)(B) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(4)(B) (B) Managers The Secretary may make written demand on an organization subject to penalty under subparagraph (A) specifying in such demand a reasonable future date by which the notice shall be submitted for purposes of this subparagraph. If such notice is not submitted on or before such date, there shall be pa…