IRCCourt RulingsFeb 9, 2023★ strong match
s of the Code as of the dates the
corresponding provisions of law are repealed by the Code, until
superseded by regulations issued under the Code.
111 As explained later, regulations related to sec . 482 of the Internal Revenue
Code of 1954 were promulgated in 1962. Regulation sec. 1.482-1, T.D. 6595, 27 Fed.
Reg. 3597…
88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 2, 2023
…)(1)(ii)(B) and (c)(1)(ii)(B), 29 CFR 2590.715-2713A(b)(1)(ii)(B) and (c)(1)(ii)(B), and 45 CFR 147.131(d)(1)(ii)(B) of the current rules, which are redesignated as 26 CFR 54.9815-2713A(b)(1)(ii)(B) and (c)(1)(ii)(C), 29 CFR 2590.715-2713A(b)(1)(ii)(B) and (c)(1)(ii)(C), and 45 CFR 147.131(b)(1)(ii)(B) in these propose…
IRCCourt RulingsFeb 22, 1989
…eral Explanation of the Revenue Act of 1978, p. 74 (Comm. Print 1979). The Congress amended section 131 of R.A. 1978 by section 252 of TEFRA, Pub. L. 97-248, 96 Stat. 324, 532. This provision made the amendments made by section 131 of R.A. 1978 inapplicable to qualified State judicial plans. On its facé, the language o…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…4, rounded to $159.
Back to Citation
154. As of 2023, PSN estimated that their members represented 185,000 employer-sponsored retirement plans. (Portability Services Network,
A Retirement Industry-Led Utility,
(2023),
https://psn1.com/learning-center/about-psn/a-retirement-industry-led-utility.)
Back to Citation
15…
88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
…ck to Citation
306. The total annual burden reduction for the Federal government is calculated as: 185 plans × 15 minutes = 46 hours. A labor rate of $53.67 is used for an HHS employee. The labor rate is applied in the calculation as: 185 plans × 15 minutes × $53.67 = $2,469.
Back to Citation
307.
The total annual bu…
IRCCourt RulingsMar 20, 1997
… day, Dura-Craft also paid the balance of its corporate loan
by issuing a check to the Plan for $87,185 with the notation
"princ $50,000, int $37,185". Dura-Craft's check register for
the $87,185 check to the Plan bears the notation "Loan Payback
from Milo-Dave-pd directly to Dura-Craft profit Share Trust."
Springbrook…
IRCCourt RulingsAug 10, 2015★ strong match
mmissioner, 131 T.C. 185 (2008), supplementing T.C. Memo.
2007-340; Cyman v. Commissioner, T.C. Memo. 2009-144.
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II. Section 1839
A. General Law Generally, the Internal Revenue Code allows deductions for ordinary and
necessary expenses incurred in conducting a trade or business or for the
production of income. Se…
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
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
.
Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t… IRCRevenue ProceduresSuperseded Jan 4, 2021
…OR EMPLOYEE PLANS RULINGS AND AGREEMENTS DECLINES TO ISSUE A LETTER RULING OR DETERMINATION LETTER?
185
.01 In general
185
.02 Notification of appropriate Service official
185
.03 Refunds of user fees
185
PART II. PROCEDURES FOR DETERMINATION LETTER REQUESTS
PART IIA. REQUESTING DETERMINATION LETTERS
SECTION 8. IN WHAT…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20… IRCRevenue ProceduresJan 2, 2019
…DETERMINATION LETTER FILING PROCEDURES FOR GROUP TRUSTS?
184
.01 Scope
184
.02 Required information
185
.03 Forms
185
SECTION 17. WHAT ARE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMINATION OF LEASED EMPLOYEE STATUS?
185
.01 Scope
185
.02 Employer must request the determination under § 414(n)
185
.03 Forms
186
.04…
IRCCourt RulingsJul 25, 1974related by meaning
ew principal place of work.
Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217.
SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
82 FR 47792 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…
In general. Beginning at the time described in paragraph (b) of this section and subject to §§ 147.131 and 147.132, a group health plan, or a health insurance issuer offering group or individual health insurance coverage, must provide coverage for and must not impose any cost-sharing requirements (such as a copayment,…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…for or supported to the extent they exceed the exemptions and accommodation set forth in 45 CFR 147.131 and 147.132. Previous versions of the regulation placed that limit in 45 CFR 147.130(a)(1), but did not reiterate it in § 147.130(a)(1)(iv). To clearly set forth the applicability of the exemptions and accommodation,…
IRCCourt RulingsAug 19, 2003
…d from Vanguard Fiduciary
Trust Co. (Vanguard) two retirement plan distributions in the
amounts of $131,555 ($131,555 retirement plan distribution) and
$42,704 ($42,704 retirement plan distribution), respectively.
Vanguard issued to petitioner Form 1099-R, Distributions From
- 3 -
2
The actual amount that petitioner de…
82 FR 47838 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…her amended in paragraphs (a)(1) introductory text and (a)(1)(iv) by removing the reference “§§ 147.131 and 147.132” and adding in its place the reference “§§ 147.131, 147.132, and 147.133”.
§ 147.131
[Amended]
8. Section 147.131, as revised elsewhere in this issue of the Federal Register
, is further amended—
a. In pa…