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1. 91 FR 33900 — Federal Independent Dispute Resolution Operations
   IRCFinal Rules (FR)Jun 4, 2026
   …lection authorities to collect any such debts,[198] including netting in accordance with 45 CFR 156.1215, as applicable, as part of HHS' integrated monthly payment and collections cycle. Additionally, since the Departments are not finalizing the proposed direct Departmental collection of the administrative fee and to e…
2. 88 FR 75744 — Federal Independent Dispute Resolution Operations
   IRCProposed Rules (FR)Proposed Nov 3, 2023
   …82.  HHS intends to propose in notice and comment rulemaking in the near future to amend 45 CFR 156.1215 to provide that administrative fees for utilizing the No Surprises Act Federal IDR process for health insurance issuers that participate in financial programs under the ACA would be subject to netting as part of HHS…
3. 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…
4. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
   IRCCourt RulingsOct 19, 2010related by meaning
   ollars, petitioner's persistence in pursuing a tax protest agenda is inexcusable'" and "A penalty in the maximum amount of $25,000 is appropriate when lesser amounts have not deterred a taxpayer's defiance of the tax laws and of the rulings of the courts." Id. (quoting January 11, 2008, order and order to show cause). …
5. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
   IRCCourt RulingsMay 25, 2005related by meaning
   ibution was not from an IRA, it would not qualify for the exception for higher education expenses, even if it were used for higher education expenses. Petitioners stated in their petition that the distribution was from a section 401(k) account, a fact which petitioners have not denied. Petitioners did not respond to th…
6. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
   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…
7. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
   IRCCourt RulingsJul 31, 2000
   …974). Commissioner , supra at 443; see also Loftin & Woodard, Inc. v. United States , supra at 1214-1215; Crosby v. United States , supra at 1388; Magnon v. Commissioner , 73 T.C. 980, 993-994 (1980). Petitioners argue that the excess contributions were paid to the employee/owners as compensation for their services. We…
8. 29 C.F.R. § 2570.163 — Parties, how designated.
   ERISARegulationsJan 1, 2017related by meaning
   For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
9. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
   IRCCourt RulingsMar 20, 1997
   …tates , 621 F.2d 731, 735 (5th Cir. 1980); Loftin & Woodard, Inc. v. United States , 577 F.2d 1206, 1215 (5th Cir. 1978); Noble v. Commissioner , supra at 443; Magnon v. Commissioner , supra at 993-994. When a corporation confers an economic benefit upon a shareholder in his capacity as such, without an expectation of …
10. 29 C.F.R. § 2570.113 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
11. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    rticle 12 of Law No. 4,131, of September 3, 1962. ANTONIO DELFIM NETTO The English portion of Exhibit 31 - J (Portaria 60/94 ) is: MF Ordinance No. 60 D.O.U.: 2/01/1994 The MINISTER OF FINANCE, in exercise of its statutory duties, taking into view the provisions of art. 50 of Law No. 8,383, of December 30, 1991 and Ord…
12. T.C. Memo. 1998-64 — Reed Smith Shaw & McClay; William J. Smith, Tax Matters Partner v. Commissioner
    IRCCourt RulingsFeb 17, 1998
    … term "possession" means "physical" possession of the security. Wagner v. Hart Chem. Co. , supra at 1215. In this case, the tax matters partner has not shown that delivery of the Saztec stock was made to the trust under section 8313(a) of the Pennsylvania Commercial Code between April 7, 1987, when the contribution agr…
13. 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, 2017related by meaning
    CTION: Notice of proposed rulemaking by cross-reference to temporary regulations. ( printed page 47657) SUMMARY: In this issue of the Federal Register , the Department of Treasury and the IRS are issuing two sets of temporary regulations related to section 9815 of the Internal Revenue Code. The first set of temporary r…
14. 72 T.C. 117 — Dallas Dental Lab, Inc. v. Commissioner
    IRCCourt RulingsApr 12, 1979
    …n greater than that allowed by the terms of the plan. Irwin B. Schwabe Co. v. Commissioner, 17 T.C. 1215 (1952). Therefore, we hold that the respondent properly excluded the compensation paid to individuals employed by petitioner for less than 5 months in computing the limitation on deduction for contributions to the p…
15. 29 C.F.R. § 2570.4 — Parties.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
16. 39 T.C. 362 — Wilson v. Commissioner
    IRCCourt RulingsNov 6, 1962
    …h pensions, profit-sharing plans, and annuities, this Court stated in Irwin B. Schwabe Co., 17 T.C. 1215, 1220, referring specifically to section 23(p)(l)(A), I.K..C. 1939, that— In the applicable revenue laws the loss of such benefits (under pension plan] is commonly referred to as a forfeiture of employees’ benefits.…
17. 29 C.F.R. § 2570.63 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(2) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
18. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987
    …novan v. Walton, 609 F. Supp. 1221, 1246 (S.D. Fla. 1985); McDougall v. Donovan, 552 F. Supp. 1206, 1215 (N.D. Ill. 1982); Freund v. Marshall & Ilsley Bank, 485 F. Supp. 629, 637 (W.D. Wis. 1979); Marshall v. Kelly, 465 F. Supp. 341, 354 (W.D. Okla. 1978). As the Fifth Circuit in Donovan v. Cunningham, supra, stated: T…
19. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
20. TR 2011-01 — Technical Release 2011-01
    ERISADOL Technical ReleasesMar 18, 2011
    …1 (877) 881-6388 www.insurance.pa.gov Puerto RicoPuerto Rico Oficina de la Procuradora del Paciente 1215 Ponce de Leon PDA 18 Santurce, PR 00907 (800) 981-0031 www.pacientes.gobierno.pr querellas@opp.gobierno.pr Rhode IslandRhode Island Department of Business Regulation 1511 Pontiac Avenue, Bldg 69-2 Cranston, RI 02920…