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72 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    …plication requirements at 26 CFR 54.9812-1(c)(4)(i)(A), 29 CFR 2590.712(c)(4)(i)(A), and 45 CFR 146.136(c)(4)(i)(A), rather than as proposed at 26 CFR 54.9812-1(c)(4)(ii)(A), 29 CFR 2590.712(c)(4)(ii)(A), and 45 CFR 146.136(c)(4)(ii)(A) because, as discussed earlier in this preamble, these final rules structure the des…
  2. 88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCProposed Rules (FR)Proposed Aug 3, 2023
    ….200(a)(4)(ii)(B). Back to Citation 172.  26 CFR 54.9815-2719, 29 CFR 2590.715-2719, and 45 CFR 147.136. Back to Citation 173.   But see26 CFR 54.9812-1(e)(4), 29 CFR 2590.712(e)(4), and 45 CFR 146.136(e)(4), which explains how these requirements interact with the requirement to provide EHBs under 45 CFR 147.150 and 15…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  4. TR 2023-01P — Technical Release 2023-01P
    ERISADOL Technical ReleasesJul 25, 2023
    …sed 26 CFR 54.9812-1(c)(4)(i) or (c)(4)(ii), 29 CFR 2590.712(c)(4)(i) or (c)(4)(ii), and 45 CFR 146.136(c)(4)(i) or (c)(4)(ii). Further, under the proposed rules, if finalized, the plan or issuer would be required to:Take reasonable action to address the material differences in access as necessary to ensure compliance,…
  5. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    …ipal issue presented is whether the petitioner corporation's $171,476 "employer reversion", section 4980(c)(2)(A), which is concededly includable in its gross income, may be offset by a section 162(a)(1) deduction in the same amount for compensation paid to its sole stockholderemployee. The facts have been stipulated. …
  6. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    ntentional disregard of rules and regulations." Additionally, they make no argument on brief concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have conceded the additions to tax pursuant to section 6653. Petitioners and the corporation argue that, to t…
  7. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
  8. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …nual respondent time cost Printing and mailing costs (labor cost included) * Total estimated cost 3,498,942 3,498,942 2.0 3,538,305 $354,512,803 $2,214,961 ** $356,727,765
  9. 45 T.C. 133 — Jacobs v. Commissioner
    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 …
  10. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995★ strong match
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTE…
  11. Treas. Reg. § 1.408-4(c)(4) — Treatment of distributions from individual retirement arrangements.
    IRCRegulationsMay 18, 2016
    …uted to A from his individual retirement account. As of such date, the balance of the account is $1,498 [$1,605 − $107]. There were no other distributions from the account as of such date. The net amount of income earned by the account is $105 [$1,498 + $107 − (0 + $1,500)]. The net income attributable to the excess co…
  12. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    … Proposed net adjustment $23,651,332 51 Another adjustment in the notice of deficiency was a $4,751,136 increase in income of the 3M consolidated group for “Support Service Fee--3M do Brasil LTDA”. The notice of deficiency explained this “Support Service Fee” adjustment as follows: It is determined that an adjustment i…
  13. T.C. Summary Opinion 2005-78 — Hossam Helmy El-Bibany & Salma Hassan Kandil v. Commissioner
    IRCCourt RulingsJun 8, 2005
    ein, the Higher Education Amendments of 1986, Pub. L. 99-498, sec. 406, 100 Stat. 1454, 20 U.S.C. sec. 108711(3) (Supp. IV 1998) added sec. 472 to the Higher Education Act of 1965. The purpose of this section was to define “cost of attendance” in determining a student’s financial need for student financial aid assistan…
  14. 86 FR 68560 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 3, 2021
    …n for part 4044 continues to read as follows: Authority: 29 U.S.C. 1301(a), 1302(b)(3), 1341, 1344, 1362. 2. Appendix D to part 4044 is amended by removing Table I-21 and adding in its place Table I-22 to read as follows: Appendix D to Part 4044—Tables Used To Determine Expected Retirement Age Table I-22—Selection of R…
  15. 85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights
    ERISAProposed Rules (FR)Proposed Sep 4, 2020
    …usions from Public Hearings (Jan. 1985) (1985 DOL Report), included in 1985 ERISA Hearings, at 454, 498 (“Projections are that ERISA plans will hold more than half of all the equity securities in the United States before the turn of the century. Perhaps not entirely by coincidence, take-over fever reached epidemic prop…
  16. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  17. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
    IRCProposed Rules (FR)Proposed Dec 30, 2014
    …ice of Modification 1,160,000 719,200 11,987 354,805 11,987 354,805 Total 62,909,328 39,059,864 652,498 19,313,933 652,498 19,313,933 The Departments note that persons are not required to respond to, and generally are not subject to any penalty for failing to comply with, an ICR unless the ICR has a valid OMB control n…
  18. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  19. 80 FR 72192 — Final Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, Dependent Coverage, Appeals, and Patient Protec…
    IRCFinal Rules (FR)Nov 18, 2015
    …ments. 4. ICRs Regarding Affordable Care Act Internal Claims and Appeals and External Review (§§ 14.136 (b)(2)(ii), 147.136 (b)(2)(ii)(C), 147.136 (b)(3)(ii), 147.136 (b)(3)(ii)(C)) Paragraph (b)(2)(ii)(C) of the final regulations implementing PHS Act section 2719 provides that non-grandfathered ERISA-covered group hea…
  20. Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o…
    IRCRevenue ProceduresOct 17, 2016
    …n contravention of § 401(a)(30)) . . .. . .. . .. . ............................................... 498 .05 Exclusion of an eligible employee from all contributions or accruals under the plan for one or more plan years .......................................... 498