82 FR 6244 — Regulations Governing Retirement Savings Bonds IRCFinal Rules (FR)Jan 19, 2017
…ading of subpart B to read as follows:
Subpart B—Treasury's Retirement Savings Program
7. Revise §§ 347.10 and 347.11 to read as follows:
§ 347.10
Authorized form of registration.
(a) Retirement savings bonds are issued to the IRA custodian for Treasury's retirement savings program. No other registrations under this su…
79 FR 74023 — Regulations Governing Retirement Savings Bonds IRCFinal Rules (FR)Dec 15, 2014
… a significant regulatory action pursuant to Executive Order 12866.
List of Subjects in 31 CFR Part 347
Government securities
Savings bonds
Accordingly, for the reasons set out in the preamble, amend 31 CFR Chapter II, Subchapter A, by adding part 347 to read as follows:
PART 347—REGULATIONS GOVERNING RETIREMENT SAVING…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
(45 CFR 147.132(a)(1)(i)(A))
F. Nonprofit Organizations (45 CFR 147.132(a)(1)(i)(B))
G. Closely Held For-Profit Entities (45 CFR 147.132(a)(1)(i)(C)) H. For-Profit Entities That Are Not Closely Held (45 CFR 147.132(a)(1)(i)(D))
I. Other Non-Governmental Employers (45 CFR 147.132(a)(1)(i)(E))
J. Plans Established or Ma…
82 FR 47838 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…he Federal Register , is amended in paragraph (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”.
§ 54.9815-2713AT
[Amended]
3. Section 54.9815-2713AT, as added elsewhere in this issue of the Federal Register
], is amended—
a. In paragraph (a…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
IRCCourt RulingsFeb 9, 2023★ strong match
until the
restriction was lifted. Id. The Tax Court held that because section 482
of the Internal Revenue Code of 1954 does not apply, the regulations under section 482 of the Internal Revenue Code of 1954 do not apply.
Procter & Gamble Co. v. Commissioner , 95 T.C. at 340-341. Excerpted
in full below is the Tax Court’…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
82 FR 47792 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…health plan established or maintained by a house of worship or integrated auxiliary.
3. Section 147.132(a)(1)(i)(B)
Section 147.132(a)(1)(i)(B) of the rules specifies that the exemption includes the plans of plan sponsors that are nonprofit organizations.
4. Section 147.132(a)(1)(i)(C)
Under § 147.132(a)(1)(i)(C), the …
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…
88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
labor rate of $132.38 is used for a general or operations manager and a labor rate of $109.96 is used for a business operations specialist. (
Source: Estimates for total compensation are based on mean hourly wages by occupation from the 2021 Occupational Employment Statistics and estimates of wages and salaries as a p…
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
.
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…al Register , is further amended in paragraph (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”.
§ 54.9815-2713A
[Amended]
3. Section 54.9815-2713A, as amended elsewhere in this issue of the Federal Register
, is further amended—
a. In parag…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
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…
IRCCourt RulingsNov 25, 2008related by meaning
e Tax Court
(and the Tax Court shall have
jurisdiction) to determine the
appropriate relief available to the
individual under this section * * *
- 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4
This amendment applies "with respect to liability for taxes
arising or remaining unpaid on or after …
IRCCourt RulingsNov 21, 2023related by meaning
n its trade
or business, including “ rentals or other payments required to be made
as a condition to the continued use or possession ” of property.
19 Respondent also contends that petitioners failed to substantiate some of the
reported rent payments. Because we sustain respondent’s determination on other
grounds, we n…