24 T.C. 460 — Northwest Automatic Products Corp. v. United States IRCCourt RulingsJun 23, 1955related by meaning
a determination of whether we had jurisdiction or not once it should be held that the method prescribed by statute is not the exclusive method. * * * See also, Henry Wilson, 16 B. T. A. 1280 (1929); William M. Greve, 37 B. T. A. 450 (1938); John A. Gebelein, Inc., 37 B. T. A. 605 (1938); Oscar Block, 2 T. C. 761 (1943…
IRCCourt RulingsMar 31, 2015related by meaning
ayer liable for tax if the taxpayer fails to pay the tax within 10 days
after notice and demand for payment. Section 6330(a) provides that no levy may be made on any property or right to property of any person unless the Secretary
has notified such person in writing of the right to a hearing before the levy is
made. Se…
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…
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 RulingsMay 6, 2014related by meaning
on 6301 empowers the Commissioner to collect the taxes imposed by
the internal revenue laws. To further that objective, Congress has provided that the Commissioner may effect the collection of taxes by, among other methods, liens
and levies. Section 6321 imposes a lien in favor of the United States on all
property and …
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…
IRCCode / StatuteJan 24, 2020related by meaning
(c)(18)(D)(iv) (iv) the requirements of section 401(a)(30) are met.
(c)(19) (19) A post or organization of past or present members of the Armed Forces of the United States, or an auxiliary unit or society of, or a trust or foundation for, any such post or organization— [(20) Repealed. Pub. L. 113–295, div. A, title II,…
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…
ERISA § 3002(e) (29 U.S.C. § 1202) — Procedures with respect to continued compliance with Internal Revenue requirements relating to participation, vesting, and funding standards ERISACode / StatuteJan 5, 2015related by meaning
(e) (e) Consultative requirements respecting promulgation of proposed or final regulations The Secretary of the Treasury shall consult with the Pension Benefit Guaranty Corporation with respect to any proposed or final regulation authorized by subpart C of part I of subchapter D of chapter 1 of title 26, or by sections…
Joint BoardRegulationsDec 30, 2016related by meaning
(d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved.
(d)(4)(iv) (iv) Public i…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
IRCCourt RulingsNov 6, 2012related by meaning
oneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). However,
the Commissioner bears the burden of proof with respect to any increase in deficiency. See Rule 142(a)(1). Our conclusion, however, is based on a
preponderance of the evidence, and thus the allocation of the burden of proof is
immaterial. See E…
IRCCourt RulingsJul 21, 2014related by meaning
account transcript showing that he did not file a 2009 return.
The only evidence that petitioner produced was his own uncorroborated testimony,
- 8 - [*8] which, for the reasons previously stated, we do not find credible. We will
therefore sustain the imposition of the section 6651(a)(1) addition to tax.
B. Section 66…
T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner IRCCourt RulingsJan 21, 1998related by meaning
second notice of
- 12 -
deficiency). Petitioner asserts that the 3-year period of
limitations on assessment and collection with respect to 1992 income tax deficiencies (which are joint deficiencies) and for section 4975
excise taxe s for years before 1993 had expired. Petitioner
characterizes this assertion as a jurisd…
IRCCourt RulingsJun 13, 1977related by meaning
61); Liberty Machine Works, Inc. v. Commissioner, 62 T.C. 621 (1974); Comprehensive Designers International, Ltd. v. Commissioner, 66 T.C. 348 (1976). For plan contributions made after August 1, 1969, however, the standard is that set forth in section 83, viz, whether there exists a substantial risk of forfeiture of th…
ERISARegulationsJan 1, 2017related by meaning
(j) (j) Liability.
(j)(1) (1) If more than one person is responsible as administrator for the failure to file the annual report, all such persons shall be jointly and severally liable with respect to such failure.
(j)(2) (2) Any person against whom a civil penalty has been assessed under section 502(c)(2) pursuant to a…
89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAFinal Rules (FR)Jan 24, 2024related by meaning
bbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds or securities; or (ii) A statement describing the applicable investigation, examination, litigation, or controversy; and
(12)(i)(A) Either a statement that, within the last 13 years, the …
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 RulingsFeb 12, 2014related by meaning
required to disclose in that return
all of the assets that it held at the end of 2005 and the respective yearend values of
all of those assets.
- 7 - Under IRC section 4979[A](e)(2)(C), all the deemed owned shares of
all the disqualified persons with respect to the Law Office of John H
Eggertsen P. C. Employee Stock O…