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61. 78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-…
    IRCFinal Rules (FR)Nov 13, 2013
    …ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended. List of Subjects 26 CFR Part 54 Excise taxes Health care Health insurance Pensions Reporting and recordkeeping requirements 29 CFR Part 2590 Continuation c…
62. 31 T.C. 1182 — Finnie Co. v. United States
    IRCCourt RulingsMar 24, 1959related by meaning
    s for such determination. Such statement shall not be used in the Tax Court of the United States as proof of the facts or conclusions stated' therein. “This subsection shall be applicable to all contracts and subcontracts, to the extent of the amounts received or accrued thereunder in any fiscal year ending after June …
63. 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…
64. I.R.C. § 6652(j) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (j) (j) Failure to file certification with respect to certain residential rental projects In the case of each failure to provide a certification as required by section 142(d)(7) at the time prescribed therefor, unless it is shown that such failure is due to reasonable cause and not to willful neglect, there shall be pa…
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. 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…
67. 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 …
68. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    statutory provisions and the legislative histories of those provisions, we hold that petitioner's use of the distributions from his Keogh and IRA's to purchase stock which he then contributed to the Smith Barney IRA does not constitute a tax-free rollover contribution under section 402(c) or 408(d)(3), respectively. 3 …
69. 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…
70. 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 …
71. 29 C.F.R. § 2570.168 — Decision of the administrative law judge.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.57 of this title.
72. 29 C.F.R. § 2560.502i-1(e) — Civil penalties under section 502(i).
    ERISARegulationsJan 1, 2017related by meaning
    (e) (e) Computation of the section 502(i) penalty. (e)(1) (1) In general, the civil penalty under section 502(i) is determined by applying the applicable percentage (five percent or one hundred percent) to the aggregate amount involved in the transaction. However, a continuing prohibited transaction, such as a lease or…
73. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006related by meaning
    198 99 (1931); H.R.Rep. No. 708, 72nd C ong., 1939-1 C.B. (Part 2) 457, 490-91; S.Rep. No. 665, 72nd Cong., 1939-1 C.B. (Part 2) 496, 532. The Supreme Court has recognized this purpose on several occasions. In United States v. O'Malley , 38 3 U.S. 6 27, 631, 86 S. Ct. 1123, 1126, 16 L. Ed. 2d 45 ( 1966), it was stated …
74. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013related by meaning
    or disbarment of any practitioner". 31 C.F.R. sec. 10.4(a)(2007). - 6 - or the Form 1099-R issued by Guardian.5 After preparing the return, Mr. Neuman reviewed it with petitioners, who then timely filed it. In March 2012 respondent issued to petitioners a notice of deficiency for 2010, determining a deficiency of $6,94…
75. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002related by meaning
    ot entitled to IRA contribution deductions because they did not substantiate their IRA deductions. Finally, respondent determined that petitioners are liable for an accuracy-related penalty due to a substantial understatement of income tax. Discussion In general, the determinations of the Commissioner in a notice of de…
76. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    ents of section 2039(c)(3). Due to concessions and in order to reflect petitioner’s claim for an overpayment, Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
77. 131 T.C. No. 15 — Larry G. & Maria A. Walton Mitchell v. Commissioner
    IRCCourt RulingsDec 15, 2008related by meaning
    ion T.C. Memo. 1998-274. There would also be some perverse consequences of construing the phrase “not be treated as a precedent” in section 7463(b) as a bar on subsequent citation for purposes of res judicata , collateral estoppel, and law of the case. Section 6512 generally deprives other federal courts of jurisdictio…
78. T.C. Summary Opinion 2012-103 — Gary Wayne Doolittle v. Commissioner
    IRCCourt RulingsOct 25, 2012related by meaning
    obligation was paid by a trust, not by him. See Amarasinghe v. Commissioner, T.C. Memo. 2007-333. He is not entitled to the claimed alimony deduction. II. Accuracy-Related Penalty Respondent determined an accuracy-related penalty under section 6662(a) and (b)(1) and (2) for underpayments attributable to negligence or a…