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…
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)(…
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…
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…
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…
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…
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…
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…
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…
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 …
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…
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…
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…
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…
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…
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…
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…
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…
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
…
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…