83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…0(a)(1) and (a)(1)(iv)).
2. Exemption for Objecting Entities Based on Moral Convictions (45 CFR 147.133(a))
3. Exemption for Certain Plan Sponsors (45 CFR 147.133(a)(1)(i))
a. Plan sponsors in general (45 CFR 147.133(a)(1)(i) prefatory text)
b. Nonprofit organizations (45 CFR 147.133(a)(1)(i)(A))
c. For-Profit Entities…
IRCCourt RulingsFeb 9, 2023related by meaning
Commissioner , T.C. Memo.
1993- 616, 66 T.C.M. (CCH) 1707 (1993), aff’d sub nom.
Texaco, Inc. , & Subs. v. Commissioner , 98 F.3d 825 (5th
Cir. 1996). In petitioner’s view, “these precedents control the outcome here.”
Respondent disagrees with this. He contends that the jud icial opinions
did not determine the statutor…
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…
IRCCourt RulingsSep 13, 2017
…nguard Fiduciary Trust Co. (Vanguard). It is
undisputed that petitioner received a distribution of $133,501 from Vanguard
during 2012. As of the close of that year petitioner was under 59½ years of age.
Vanguard sent the Internal Revenue Service (IRS) and petitioner a Form
1099-R, Distributions From Pensions, Annuities…
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 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)(1) by removing “or (ii)” and adding in its place “or (ii), or 45 CFR…
79 FR 56442 — Additional Rules Regarding Hybrid Retirement Plans IRCFinal Rules (FR)Sep 19, 2014
… plan years.
One commenter on the 2010 proposed regulations suggested that a special rule under the 133
1/3 percent rule of section 411(b)(1)(B) should not be provided for variable interest crediting rates that can potentially be negative. Other commenters suggested that the interest crediting rate to be used for purpo…
IRCCourt RulingsMay 22, 2025
…um. He rounded to
19% for cost of equity and WACC (for the international
segment).
Dr.
Strebulaev
2.297 none
Dr. Strebulaev did not compute a Facebook-specific
beta or discount rate in his opening or rebuttal reports.
Petitioner offers a beta for late-stage private company
investments from his 2016 paper, Ewens, Rhodes…
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…
IRCRegulationsSep 9, 2016
…iod is the calendar year. Even though no single accrual rate under the J Corporation's plan exceeds 133 1/3 percent of the immediately preceding accrual rate, the J Corporation's plan does not satisfy the requirements of this subparagraph because the rate of accrual for all years of participation in excess of 10 (1 7/9…
IRCCourt RulingsOct 9, 1997★ strong match
…deduction on the basis of the
following calculation. The fund balance on November 30, 1986,
was $11,297,108. Petitioner contributed $27 million to the VEBA
Trust during December 1986, which under the regulation is deemed
part of the November 30, 1986, yearend balance, equal to
$38,297,108. As was mentioned supra
, any …
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
…ing 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (1957), relied upon by petitioner, are clearly distinguishable on their facts.
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
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’ …
IRCCourt RulingsAug 24, 1995related by meaning
drawn therefrom), but that, if such order were not a QDRO, petitioner’s ex-husband and not petitioner would be taxable in respect of the distribution. As will subsequently become apparent, such all-or-nothing treatment will not necessarily flow from our decision herein. Indeed, the road to decision herein is a rocky on…
82 FR 47656 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act; Proposed Rulemaking IRCProposed Rules (FR)Proposed Oct 13, 2017
…a. In paragraph (a)(1) by removing the language “(ii)” and adding in its place “(ii), or 45 CFR 147.133(a)(1)(i) or (ii)”. b. In paragraph (a)(2) by adding the language “or 147.133(a)” after “147.132(a)”.
c. In paragraph (b)(1)(ii) introductory text by removing the language “147.132” and adding in its place “147.132(ii…
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
…by the amount of the AIR ($500,000 − $300,000). The reduced deduction limit is then applied to O’s $133,333 of DDR attributable to services performed by O in L’s 2017 taxable year that is paid in 2018. Because $133,333 does not exceed that reduced deduction limit of $200,000, the $133,333 is deductible for 2018. The de…
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 RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
83 FR 27898 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Jun 15, 2018
…)
On or after
Before
i1
i2
i3
n1
n2
* * * * * * *
297
7-1-18
8-1-18
1.25
4.00
4.00
4.00
7
8
3. In appendix C to part 4022, Rate Set 297 is added at the end of the table to read as follows:
Appendix C to Part 4022—Lump Sum Interest Rates for Private-Sector Payments
* * *…
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…