IRCCourt RulingsApr 19, 2004related by meaning
the payment of such tax. * * *
Section 6334(a) exempts from levy: (1) Wearing apparel and
school books; (2) fuel, provisions, furniture, and personal effects; (3) books and tools of a trade, business, or profession;
(4) unemployment benefits; (5) undelivered mail; (6) certain
annuity and pension payments; (7) workmen’…
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…
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
sing Form 8821, Tax Information Authorization. (See Form 8821 and Instructions) See section 10.09 for special rules relating to Anonymous Submissions. .08 Penalty of perjury statement. (1) The Plan Sponsor must sign the penalty of perjury statement on the Form 8950 as part of a VCP submission. In addition, the followin…
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…
IRCCourt RulingsSep 24, 2002related by meaning
titioner is not
liable for the sec. 6662 penalty.
3
S.K. apparently stands for Smoothie King, which we gather
was the trade name of a product.
OPINION DAWSON, Judge
: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to section 7443A(b)(3) and
Rules 180, 181, and 182.
1
The Court agrees with and…
IRCCourt RulingsAug 8, 2000related by meaning
S.C. section 362(c)(2)(C),
wherein the stay of “any other act” is lifted upon order of
discharge in a chapter 11 bankruptcy proceeding. The proceeding before us is not an act against the property of the bankruptcy
estate per 11 U.S.C. section 362(c)(1). See Bigelow v.
Commissioner
, 65 F.3d 127, 128 (9th Cir. 1995).
We…
IRCCourt RulingsOct 9, 2007related by meaning
ers . In response to
our leniency, petitioner once again ignored our Rules and our
order .
-5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a
sanction pursuant to Rule 123(b) . See Stringer v . Commissioner ,
84 T .C . 693, 704-705 (1985), affd . withou…
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…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
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 …
IRCCourt RulingsApr 20, 2017related by meaning
onstrain an IRS examiner's ability to consider a hardship waiver during
the course of an examination. Certainly no such constraint is found in section 402(c)(3)(B). Moreover, respondent's position appears to be at odds with Internal
7Rev. Proc. 2016-47, supra, was issued after the parties had filed their
posttrial brie…
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…
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.
…
IRCCourt RulingsMar 19, 2025related by meaning
United States Tax Court
T.C. Memo. 2025-23
CHARLIE CAMPANA,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
__________
Docket No. 15766-23. Filed March 19, 2025.
__________
Charlie Campana , pro se.
Bianca L. Thomas and Daniel C. Munce, for respondent.
MEMORANDUM FINDINGS OF FACT A ND OPINION
PUGH , Judge : …
IRCCourt RulingsNov 18, 2021related by meaning
equirem ents of section 408(a), and we do not interpret it to
- 19 -
create an exception to those requirem ents in the absence of express wording that does so. In m atters of statutory interpretation, “[w] e assum e that Congress is aware
of existing law when it passes legislation.” Miles v. Apex Marine Corp., 498 U.S.…
80 FR 79684 — Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated IRCFinal Rules (FR)Dec 23, 2015related by meaning
l for Advocacy of the Small Business Administration for comment on their impact on small business, and no comments were received.
Drafting Information The principal authors of these regulations are Mike Repass and Jonathan Carter, Office of Associate Chief Counsel (Tax-Exempt and Government Entities). However, other pe…
87 FR 80042 — Exception for Interests Held by Foreign Pension Funds IRCFinal Rules (FR)Dec 29, 2022related by meaning
ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development.
( printed page 80055) List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended a…
IRCCourt RulingsMar 5, 2018related by meaning
ondent learned of those transactions during respondent's
examination[.]").
Because petitioners did not file Forms 5329, the periods of limitations for excise tax under sec. 4973 never began to run. See Paschall v. Commissioner, 137
T.C. 8, 15-17 (2011). Therefore the excise taxes respondent seeks to assess
against peti…
IRCPrivate Letter RulingsApr 2, 1999related by meaning
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
December 17, 1998
CC:DOM:FS:CORP
Number: 199913003
Release Date: 4/2/1999
Number:TL - N - 748-98
UILC: 1502.90-01
404.15-00
INTERNAL REVENUE SERVICE NATIONA L OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR ASSOCIATE DISTRICT COUNSEL
FROM: DEBORAH A.…
IRCCourt RulingsMar 14, 2019related by meaning
ho conducted petitioner's CDP hearing, a USPS document relating to the
notice of deficiency for 2012, and a copy of this Court's order and decision in Wesley v. Commissioner, docket No. 6560-14L.
At trial petitioner offered and we admitted into evidence a screen shot of
information he had downloaded from the USPS track…