IRCCourt RulingsAug 1, 1996related by meaning
7 (1987); Hays Corp. v.
Commissioner
, 40 T.C. 436 (1963), affd. 331 F.2d 422 (7th Cir.
1964); see sec. 7442. The Court has no authority to disregard the express provisions of statutes adopted by Congress, even
where the result in a particular case seems harsh. See, e.g.,
Estate of Cowser v. Commissioner
, 736 F.2d 116…
85 FR 66219 — Effect of Section 67(g) on Trusts and Estates IRCFinal Rules (FR)Oct 19, 2020related by meaning
ion of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103.
Drafting Information The principal author of these regulations is Margaret Burow of the Office of Associate Chief Counsel (Passthroughs and Special Industries). Other personnel from the Trea…
IRCCourt RulingsJun 1, 1987related by meaning
significance save that the words are strung together with syntactical correctness. * * * [Hand, “Thomas Walter Swan,” 57 Yale L. J. 167, 169 (1947).] Section 4975, as added to the Internal Revenue Code by title II of ERISA, Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, imposes two levels of excise tax on a prohibited …
77 FR 66915 — Amendment of Prohibited Payment Option Under Single-Employer Defined Benefit Plan of Plan Sponsor in Bankruptcy IRCFinal Rules (FR)Nov 8, 2012related by meaning
empt and Government Entities). However, other personnel from the IRS and the Treasury Department participated in the development of these regulations. List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
( printed page 66918)
Adoption of Amendments to the Regulations
Accordingly, 26 C…
88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 2, 2023related by meaning
of Executive Order 13132.
List of Subjects
26 CFR Part 54
Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements 29 CFR Part 2590
Continuation coverage
Disclosure
Employee benefit plans
Group health plans
Health care
Health insurance
Medical child support
Reporting and recordkeepin…
IRCProposed Rules (FR)Proposed Feb 24, 2014related by meaning
health plans
Health care
Health insurance
Medical child support
Reporting and recordkeeping requirements
45 CFR Part 147
Health care
Health insurance Reporting and recordkeeping requirements, and State regulation of health insurance
John Dalrymple,
Deputy Commissioner for Services and Enforcement, Internal Revenue Ser…
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
ment on examination . . .. . ... . .. . .. . ............ 491
.09 Special rules relating to Anonymous Submissions . . ........ . .. . .. . .. . .. 491 .10 Special rules relating to Group Submissions ................................... 491
.11 Multiemployer and multiple employer plans ...................................…
75 FR 46844 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Aug 4, 2010related by meaning
endments:
PART 53—FOUNDATION AND SIMILAR EXCISE TAXES
Paragraph 1.
The authority citation for part 53 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2.
Section 53.4965-2 is amended by revising paragraphs (c)(6)(i) and (c)(6)(i)(C) to read as follows:
§ 53.4965-2
Covered tax-exempt entities.
…
Notice 2005-1 — This notice provides general and transitional guidance relating to new section 409A of the Code, added as part of the American Jobs Creation Act of 2004. Secti… IRCNoticesJan 10, 2005related by meaning
its case to the U.S. competent authority under Article 28(4)(b) or seek a bilateral mutual agreement between the U.S. and Swiss competent authorities. Verification. The status of any Swiss pension or other retirement arrangement claiming benefits under Article 10(3) is subject to verification by the U.S. tax authoritie…
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…
IRCCourt RulingsJul 13, 1995related by meaning
ues in the instant case. Consequently, respondent’s objections are sustained, and the reports will not be received in evidence.
Validity of Regulation Treasury regulations are not to be rejected unless they are unreasonable and plainly inconsistent with the revenue statutes. Rotenberry v. Commissioner, 847 F.2d 229 (5t…
IRCCourt RulingsJan 17, 2024related by meaning
9 73) is
contained within Subtitle D, Chapter 43. Section 4975 imposes “a tax”
on any prohibited transaction engaged in by any disqualified person of a tax-exempt p lan or entity ( including an IRA ) . See § 4975(a). The initial tax currently imposed is 15% of the amount involved in the prohibited transaction, rising …
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…
IRCCourt RulingsJun 14, 2012related by meaning
ed work in her capacity as Yolo's employee or officer. Consistent with
our conclusion above, we sustain respondent's disallowance of these deductiòns. IV. Additions to Tax and Penalties
A. s Burden of Proof
Respondent bears the burden of production with regard to the section
6651(a)(1) and (2) additions to tax and the …
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
o calculate current liability and to determine the required contribution are set forth.
EXEMPT ORGANIZATIONS
Announcement 2006-55 Announcement 2006-55 Aviation Safety Council, Inc., of Pasadena, CA; Budget and Credit Counseling Services, Inc., of New York, NY; and Mason Credit Counseling, Inc., of Hauppauge, NY, no lon…
IRCCourt RulingsAug 12, 1980related by meaning
.
Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…
IRCCourt RulingsAug 27, 2018related by meaning
0 and $5,379, respectively; and
(4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014
of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a)
penalties in writing by making an entry in the Correspondence Examination
Automation Case Support…
77 FR 8668 — Summary of Benefits and Coverage and Uniform Glossary IRCFinal Rules (FR)Feb 14, 2012related by meaning
rdkeeping requirements
45 CFR Part 147
Health care
Health insurance
Reporting and recordkeeping requirements, and State regulation of health insurance Steven T. Miller,
Deputy Commissioner for Services and Enforcement, Internal Revenue Service.
Approved: February 7, 2012.
Emily S. McMahon,
Acting Assistant Secretary of…
IRCCourt RulingsApr 25, 1983related by meaning
. 1348 was repealed by sec. 101(c)(1), Pub. L. 97-34,95 Stat. 183 (Aug. 13,1981).
4SEC. 401. QUALIFIED PENSION, PROFIT-SHARING, AND STOCK BONUS PLANS. (c) Definitions and Rules Relating to Self-Employed Individuals and Owner-Employees.— * * *
(2) Earned income.—
* * * * * * *
(C) Income from disposition of certain prop…
88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCProposed Rules (FR)Proposed Nov 20, 2023related by meaning
Section 170(f)(11) requires a qualified appraisal and other documentation for a charitable contribution deduction to be allowed with respect to certain contributions of property. Section 170(f)(11) also includes special rules for contributions of property other than cash (noncash charitable contributions) of more than …