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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   upplement to the Code of Federal Regulations was published in 1944. R. R egulations 111 In 1943, the Treasury Depart ment promulgated Regulations 111. Regulations 111 Relating to the Income Tax Under the Internal Revenue Code (Gov’t Prtg. Off. 1943). Like Regulations 103, Regulations 111 interpreted the provisions of t…
2. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
   IRCCourt RulingsAug 13, 1990★ strong match
   hould prevail on the substantive issues as a matter of law. Rule 121(b); Naftel v. Commissioner, supra at 529; Espinoza v. Commissioner, supra at 416. Rule 121(d) provides that “an adverse party may not rest upon the mere allegations or denials of such party’s pleading, but such party’s response, by affidavits or as ot…
3. Treas. Reg. § 54.9802-1(c)(2)(iii) — Prohibiting discrimination against participants and beneficiaries based on a health factor.
   IRCRegulationsDec 30, 2016
   …se of F's claims experience. (ii) Conclusion. See Example 1 in 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) for a conclusion that the issuer does not violate the provisions of 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) similar to the provisions of this paragraph (c)(2) because the issuer blends the rate so that t…
4. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
   IRCCourt RulingsSep 10, 2008★ strong match
   are petitioner's and respondent's cross-motions for summary ·judgment pursuant to Rule 121. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code in effect for the years in 1ssue. Rule 121(a) provides that either…
5. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
   IRCCourt RulingsMar 16, 1999related by meaning
   ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
6. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
   IRCCourt RulingsDec 11, 2003★ strong match
   …1, 1997, the threshold amount is $1,000. Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1202(a), 111 Stat. 994. application of other allowable credits). Sec. 6654(f); see sec. 31. Except in very limited circumstances not applicable to this case, see sec. 6654(e)(3)(B), section 6654 provides no exception for reasonab…
7. 78 FR 33158 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans
   IRCFinal Rules (FR)Jun 3, 2013
   ….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996). Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010). 8. In § 146.121, paragraph (f) is revised t…
8. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
   IRCCourt RulingsSep 28, 2011related by meaning
   …ral income tax. The case is before the Court on respondent's motion for summary judgment under Rule 121. Petitioner filed a response opposing the motion. The only issue for decision is whether pursuant to section 72(t) (1) petitioner is liable for a 10-percent additional tax on early distributions from a qualified reti…
9. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
   IRCCourt RulingsDec 2, 2010related by meaning
   bility for income tax for 2004 that exceeded $1,000, net of any section 31 credit, and has taken judicial notice of the fact that petitioner had a tax liability in 2003. Therefore, the Court sustains respondent's determination of the addition to tax pursuant to section 6654(a). The Court has considered all of petitione…
10. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    … applying a 3 percent discount rate. Back to Citation 235.  This is calculated 17,333/(1−0.25) = 23,111. Back to Citation 236.  The burden is estimated as follows: 23,111 claims × 2 hours + 23,111 claims × 0.25 hour = 51,999 hours. A labor rate of $105.01 is used for a medical and health services manager and a labor ra…
11. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
12. Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr…
    IRCAnnouncementsMay 9, 2005
    …and section 103(c)(4) of HIPAA. §146.125 [Corrected] 5. Section 146.125, the language “Sections 146.111 through 146.119,” is removed and the language “Section 144.103, §§146.111 through 146.119,” is added in its place. §146.143 [Corrected] 6. Section 146.143(b), the language “section 514 of the Act with respect to” is …
13. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    …n 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a domestic relations order entered January 7, 1988, by the Court of Common Pleas for Montgomery County, Pennsylvania, is not a “qualified domestic relations …
14. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    …t he did not receive these items of income or that the income he received was not taxable. See Rule 121(d). We conclude that respondent's determinations of unreported income as set forth in the notice of deficiency are correct, and those determinations are sustained. See Hardy v. Commissioner, 181 F.3d 1002, 1004 (9th …
15. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    5. Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable year in issue. Since respondent asserts that no return was filed by petitioners, respondent asserts a deficiency in the full amount of the asserted income tax liability (sec. 6211) and…
16. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    …oner's life for 2004 of $13,510. Petitifoner timely filed a petition in this Court. Discussion Rule 121(a) allows a party to move "for a summary adjudication in the moving party's favor upon all or any part of the 1 gal issues in controv rsy." Rule 121(b) directs that a decision on such a motion shall be rendered "if t…
17. T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov…
    IRCTreasury DecisionsOct 6, 2014
    ing account balance as of December 31, 2016, is $11,111 ($100,000 − $88,889), and as of December 31, 2017, is $27,778 ($250,000 − $133,333 − $88,889). (v) For purposes of attributing the $200,000 payment made on January 1, 2020, to services performed in the taxable years of S, the increase in O’s account balance during…
18. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    125 T.C. No. 5 UNITED STATES TAX COURT SERVICE EMPLOYEES INTERNATIONAL UNION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent 100 OAK STREET CORPbRATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 . saan. Ps are qualified labor. organi…
19. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    … judgment motion, and the sole argument presented in the response to the second motion is that Rule 121 does not provide for - 8 - repeated motions for summary judgment. This argument is without merit. Rule 121 does not prevent successive motions for summary judgment. We conclude that petitioners are liable for the 10-…
20. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…