88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
…al/surgical benefits covered by the plan or coverage, as further provided in this section and § 146.137. Accordingly, in complying with the provisions of PHS Act section 2726, this section, and § 146.137, plans and issuers must not design or apply financial requirements and treatment limitations that impose a greater b…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…d by the plan or coverage in the same classification, as further provided in this section and § 146.137. Accordingly, in complying with the provisions of PHS Act section 2726, this section, and § 146.137, plans and issuers must not design or apply financial requirements and treatment limitations that impose a greater b…
IRCCourt RulingsJan 17, 2024★ strong match
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 RulingsApr 2, 2024related by meaning
, 1485 (2021)
(“ [A]s this Court has long made plain, pleas of administrative
inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105,
2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is
clear, that is the…
IRCCourt RulingsNov 5, 1999
…ar
End of year
Cash $646 $2,295
Receivables 38,922 40,063
Investments
Real estate and mortgages -0- 137,270
Loans to participants:
Mortgages -0- -0Other 152,112
-0-
Total investments 152,112
137,270
Total assets 191,680 179,628
Liabilities
Total liabilities -0-
-0-
Net assets 191,680 179,628
The Form 5500 also reports …
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…mplying with paragraph (n) in §1.125-5. (2) Additional requirements under sections 105(h), 129, and 137. A written plan is required for self-insured medical reimbursement plans (§1.105-11(b)(1)(i)), dependent care assistance programs (section 129(d)(1)), and adoption assistance (section 137(c)). Any of these plans or p…
IRCCourt RulingsFeb 9, 2023★ strong match
…hen Treasury
Decision 8470, 58 Fed. Reg. 5271 (Jan. 2 1, 1993) , redesignate d the 1968
regulations
137
as 26 C.F.R. sec s . 1.482-1A and 2A (1994), effective for tax
years beginning on or before April 21, 1993.
138
The redesignated
regulations were printed in the 1996 edition of the Code of Federal
137
The 1968 regula…
IRCCourt RulingsApr 2, 2020
…........... 136 DD. Intermediary period: January 1 1-12, 2011 . . . . . . . . . . . . . . . . . . . 137
EE. Period 19: January 13 through February 15, 201 1 . . . . . . . . . . . . . 137
1. Introduction...................................... 137
2. Events .......................................... 138
3. Analysis and ho…
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
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…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…additional documentation, but for purposes of this burden analysis assume that half of claimants (6,137) do. The Departments assume that the IRO has clerical staff with a labor rate of $55.23 that will spend, on average 5 minutes per claimant preparing and forwarding the required documents, and that IROs incur an avera…
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…
IRCCourt RulingsSep 23, 2019
…is was CAD186,000, which,
according to the conversion rate (0.73921) used by both parties, equaled $137,493
at the time of purchase. Because of this inconsistency, petitioner husband's
testimony on this point was not credible. Without documentary evidence or
credible testimony supporting their claim, petitioners have n…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsFeb 24, 2016
…transferred the funds between his accounts and eventually
¹²Ancira v. Commissioner, 119 T.C. at 136-137.
¹³Ancira v. Commissioner, 119 T.C. at 137-139.
¹4Ancira v. Commissioner, 119 T.C. at 137.
- 16 -
[*16] to Mr. Carver. These actions show that he had unfettered control over the
funds. Accordingly, he was not acting …
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
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 RulingsMar 31, 1961
…15% of gross income_ _ 35, 077. 93
5 % of gross income__ 7, 059. 58
Total percentage depletion_ 42, 137. 51
Allowable depletion_ 42, 137. 51
Owens-Illinois Glass Company — Corona, California, Property — 1951
Total 100% Feldspar 25% Silica 77%
Tons produced and shipped_ 113, 981 26, 216 87, 765
Relative value times weig…