IRCCourt RulingsApr 26, 1983related by meaning
…were adopted. The Senate voted to accept the Finance Committee recommendation that proposed section 1241 be rejected.
Petitioner’s argument is unclear, but appears to be based on the following reasoning: proposed section 1241 approved cases finding a gift element in private annuity transactions in which the value of th…
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
80 FR 41318 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Jul 14, 2015
-148, 124 Stat. 119, as amended by Pub. L. 111-152, 124 Stat. 1029; Secretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012)
( printed page 41345) the Department of Labor adopts as final the interim rules amending 29 CFR part 2590 published on July 19, 2010 (75 FR 41726) and amending 29 CFR parts 2510 and 2590 publ…
IRCCourt RulingsJan 3, 2011related by meaning
s, earnings, and reasonable charges) pursuant
tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not :
rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant
to Rev. Proc . 2005-25, lsupra.
Held, further, P must include in his gross income
the excess contributiorls pursuan…
79 FR 8544 — Shared Responsibility for Employers Regarding Health Coverage IRCFinal Rules (FR)Feb 12, 2014
… term
Affordable Care Act means the Patient Protection and Affordable Care Act, Public Law 111-148 (124 Stat. 119 (2010)), and the Health Care and Education Reconciliation Act of 2010, Public Law 111-152 (124 Stat. 1029 (2010)), as amended by the Medicare and Medicaid Extenders Act of 2010, Public Law 111-309 (124 Stat…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
78 FR 39870 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Jul 2, 2013
… sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 3-2010, 75 FR 55354 (September 10, 2010).
The Department of Health and Human Services regulations are adopted pursuant to the au…
78 FR 8456 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 6, 2013
… sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 3-2010, 75 FR 55354 (September 10, 2010).
The Department of Health and Human Services regulations are proposed to be adopted pur…
IRCCourt RulingsFeb 9, 2023★ strong match
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
IRCCourt RulingsMay 25, 2005★ strong match
ibution was not from an IRA, it would not qualify for the
exception for higher education expenses, even if it were used for
higher education expenses. Petitioners stated in their petition that the distribution
was from a section 401(k) account, a fact which petitioners have
not denied. Petitioners did not respond to th…
IRCCourt RulingsMay 22, 2025
…................... 123
2. Nondelegation doctrine ................................................. 124
3. Intangible property under section 936(h)(3)(B) ........... 124
4. “Ex post” adjustments ................................................... 124
5. Commensurate with income “range” ............................ 124
…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958★ strong match
…x returns for the years 1942,1943, and -1944 based on a period of 60 months as permitted by section 124 (a),I. R. C. 1939.
Section 124 (d) of the Code provided that, if the President proclaimed the ending of the emergency period on a date that occurred within the 60-month amortization period, then the taxpayer might el…
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…
IRCRegulationsDec 30, 2016
… term Affordable Care Act means the Patient Protection and Affordable Care Act, Public Law 111-148 (124 Stat. 119 (2010)), and the Health Care and Education Reconciliation Act of 2010, Public Law 111-152 (124 Stat. 1029 (2010)), as amended by the Medicare and Medicaid Extenders Act of 2010, Public Law 111-309 (124 Stat…
IRCCourt RulingsJul 31, 2000
…for the third year was $12,095.03, and,
at the end of that year, the conversion credit balance was $124,364.78 ($77,954.39 + $53,150 - $12,095.03 + $5,355.42); the
$5,355.42 is the interest of 4.5 percent earned on the conversion
credit balance (($124,364.78 - $5,355.42) x 4.5% = $5,355.42)).
Of the conversion credit b…
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…
IRCCourt RulingsAug 28, 1996related by meaning
xable year. The prior notice,
mailed on February 6, 1995 (February notice), contained a
determination of an income tax deficiency and accuracy-related penalty under section 6662 for petitioner's 1991 tax year.
Petitioner questioned the validity of the August notice in his
petition filed in this case. The excise tax and…
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…
78 FR 33158 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans IRCFinal Rules (FR)Jun 3, 2013
… sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 1-2011, 77 FR 1088 (January 9, 2012).