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80 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. Treas. Reg. § 54.9802-4(f)(1)(xii) — Special Rule Allowing Integration of Health Reimbursement Arrangements (HRAs) and Other Account-Based Group Health Plans with Individual Health Insurance Cover…
    IRCRegulationsAug 19, 2019
    …nal group health plan; hourly employees offered an HRA (f)(1)(xii)(A) (A) Facts. Plan Sponsor J has 163 salaried employees and 14 hourly employees. For 2020, Plan Sponsor J offers its 163 salaried employees a traditional group health plan and each of its 14 hourly employees an HRA on the same terms. Plan Sponsor J reas…
  2. 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)(…
  3. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …,769 Printing and Postage Cost Additional Pension Benefit Statements (Year 2) 1 $40,736,877 $64,829,163 $0 $32,414,582 Total Costs in Year 1 $133,931,975 $154,823,812 $79,988,274 $136,783,396 Total Costs in Year 2 $40,736,877 $64,829,163 $0 $32,414,582 ( printed page 9228) Transfers Total Transfers (Annual) $451,779 $7…
  4. 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…
  5. 88 FR 11388 — Extension of Import Restrictions on Archaeological and Ethnological Materials of Libya
    IRCFinal Rules (FR)Feb 23, 2023related by meaning
    nction of the United States, as described above, and therefore is specifically exempted by section 3(d)(2) of Executive Order 12866. Signing Authority This regulation is being issued in accordance with 19 CFR 0.1(a)(1), pertaining to the Secretary of the Treasury's authority (or that of his/her delegate) to approve reg…
  6. T.C. Summary Opinion 2003-99 — Barney K. & Lindy W. Huang v. Commissioner
    IRCCourt RulingsJul 23, 2003
    …and it generally may not exceed the individual’s “net investment income” for the taxable year. Sec. 163(a), (d)(1); see also sec. 163(h) (disallowing any deduction for “personal interest”). Petitioners argue that the $29,103 “investment” expense listed on their 1995 return arose as follows: Prior to being - 10 - placed…
  7. T.C. Summary Opinion 2011-16 — Paulette A. & Matthew D. Malena v. Commissioner
    IRCCourt RulingsFeb 24, 2011
    …iam 540 F.2d 821 (5th Cir. 1976). A deduction is allowed for any qualified residence interest. Sec. 163 (h) (2) (D). - Deductible interest includes interest from both acquisition and home equity indebtedness. Sec. 163(h) (3). Petitioner claimed a mortgage interest deduction of $54,356 on her return. At trial, petitione…
  8. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014related by meaning
    her traditional IRA, a qualified retirement plan for purposes of section 72(t). S_ee sec. 4974(c)(4). Petitioner wife had not attained age 59½ at the time of the July 31, 2008, distribution. Petitioner wife has not shown that she qualifies for any of the other exemptions in section 72(t)(2). See Phillips v. Commission…
  9. 76 FR 13932 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations
    IRCProposed Rules (FR)Proposed Mar 15, 2011related by meaning
    nt participated in their development. List of Subjects in 26 CFR Part 301 Employment taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, 26 CFR part 301 is proposed to be amended as follows: PART 301—PROCEDURE AND…
  10. 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 …
  11. Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of…
    IRCNoticesMay 18, 2026related by meaning
    2. Section 300.4 is amended by revising paragraphs (b) and (d) to read as follows: §300.4 Enrolled agent special enrollment examination fee. * * * * * (b) Fee. The fee for taking the enrolled agent special enrollment examination is $66 per part, which is the cost to the government for overseeing the development and adm…
  12. T.C. Memo. 2000-100 — Ronna Joan Robertson v. Commissioner
    IRCCourt RulingsMar 24, 2000
    …68 and $7,386.58 of mortgage interest during the 1993 and 1994 taxable years, respectively. Section 163(h) denies taxpayers a deduction for personal interest paid or accrued during the taxable year unless it fits within certain narrowly prescribed categories. The interest paid by petitioner on her personal car loan dur…
  13. 81 FR 31165 — Removal of Allocation Rule for Disbursements From Designated Roth Accounts to Multiple Destinations
    IRCFinal Rules (FR)May 18, 2016related by meaning
    intendent of Documents, U.S. Government Printing Office, Washington, DC 20402, or by visiting the IRS Web site at http://www.irs.gov. Special Analyses Certain IRS regulations, including this one, are exempt from the requirements of Executive Order 12866, as supplemented and reaffirmed by Executive Order 13563. Therefor…
  14. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    482-1(h)(2)(i) and (ii) (2006). 163 Petitioner contends that the Brazilian legal restrictions met some of these seven requirements. 164 We discuss 162 Title 26 C.F.R. sec. 1.482-1(h)(2)(ii)(A) (2006) requires that the foreign legal restriction be “publicly promulgated, generally applicable to all similarly situated per…
  15. 84 FR 26605 — Exception for Interests Held by Foreign Pension Funds
    IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
    timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place for the public hearing will be published in the Federal Register . Drafting Information The principal authors of these proposed regulations are Joshua Rabon, formerly with the Office of Associate Chief Counsel (Intern…
  16. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025
    … also Lipson v. Commissioner, T.C. Memo. 2012-252, at *9 ; Fowler v. Commissioner, T.C. Memo. 200 4-163. The extent of our review is to determine whether the Appeals O fficer’s decision to reject the offer was arbitrary, capricious, or without sound basis in fact or law. See Skrizowski v. Commissioner , T.C. Memo. 2004…
  17. Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2006related by meaning
    …ginal issue discount attributable to the contract is treated for federal tax purposes. (Also §§ 61, 163, 1275, 2501, and 7701.) (13) Section 115.—Income of States, Municipalities, Etc.—Whether the income of membership organizations established by states exclusively to reimburse members for losses arising from workmen’s…
  18. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    …od for which the Office of Appeals denied interest abatement and for which we sustain the denial. - 163 - [*163] Date period Period number begins Date period ends Number of days Period 1 9/12/2007 9/20/2007 9 Period 2 9/20/2007 9/27/2007 8 Period 3 12/1/2007 1/31/2008 62 Period 4 1/31/2008 3/11/2008 41 Period 5 3/11/20…
  19. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ct that a law with a secular purpose may have the effect of making the observance of some religious beliefs more expensive does not render the statute unconstitutional under the First Amendment." Black v. Commissioner , 69 T.C. 505, 510 (1977) (citation omitted). Section 72(m) has the purpose of requiring taxpayers to …
  20. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    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…