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…
IRCRegulationsDec 30, 2016
…se of F's claims experience. (ii) Conclusion. See Example 1 in 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) for a conclusion that the issuer does not violate the provisions of 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) similar to the provisions of this paragraph (c)(2) because the issuer blends the rate so that t…
T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b… IRCTreasury DecisionsDec 7, 2015related by meaning
istrator Centers for Medicare & Medicaid Services Approved: October 22, 2015
Sylvia M. Burwell, Secretary Department of Health and Human Services Note (Filed by the Office of the Federal Register on July 13, 2015, 8:45 a.m., and published in the issue of the Federal Register for July 14, 2015, 80 F.R. 40661)
DEPARTMENT…
IRCCourt RulingsFeb 22, 1989related by meaning
o any participant which exceed the limitations of section 415(b).
Paragraph (1) of subsection (d) shall not apply for purposes of this subparagraph.”. (c) Effective Date. — The amendments made by this section shall apply to taxable years beginning after December 31, 1978.
[Senate Amendment to H.R. 4961, July 23 (legisl…
IRCCourt RulingsDec 11, 2003
121 T.C. No. 19
UNITED STATES TAX COURT
FORTUNATO J. MENDES, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16032-95. Filed December 11, 2003.
P has been continuously incarcerated since June 17,
1988. For P’s 1988 taxable year, R (1) determined a tax
deficiency based upon amounts reported on inf…
78 FR 33158 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans IRCFinal Rules (FR)Jun 3, 2013
….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996).
Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010).
8. In § 146.121, paragraph (f) is revised t…
IRCCourt RulingsFeb 28, 2024related by meaning
years
beginning after the date of enactment of the Act); id. § 311(b)(2), 136
Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received).
“This is the highly reticul…
IRCCourt RulingsAug 13, 1990★ strong match
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
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 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 RulingsAug 6, 1991related by meaning
itle (other than this subsection) applies with respect to such amount. The pertinent portion of sec. 1.72-2(a)(3)(i), Income Tax Regs., is as follows: Sections 402 and 403 provide that certain distributions by employees’ trusts and certain payments under employee plans are taxable under section 72. * * * For purposes o…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
77 FR 70620 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans IRCProposed Rules (FR)Proposed Nov 26, 2012
….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996). Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010).
2. In § 146.121, paragraph (f) is revised t…
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008
are petitioner's and
respondent's cross-motions for summary ·judgment pursuant to Rule
121.
Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years in 1ssue.
Rule 121(a) provides that either…
IRCCourt RulingsDec 4, 2017
…onal alimony" is a class of alimony that a Tennessee court may
award. See Tenn. Code Ann. sec. 36-5-121(d)(1) through (g)(1). It terminates on
the death of he recipient. Id. sec. 36-5-121(g)(3). It is described as a sum of
money payable by a spouse for a determinate period and awarded "when the court
finds that rehabil…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
IRCCourt RulingsAug 31, 2021
…ay move for summary judgment regarding all or any part of the legal issues in controversy. See Rule 121(a); Wachter v. Commissioner, 142 T.C.
140, 145 (2014). We may grant summary judgment if the pleadings, stipul ations
and exhibits, and any other acceptable materials show that there is no genuine
dispute as to any ma…
78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCProposed Rules (FR)Proposed Mar 21, 2013
…, other than § 146.130 and the provisions with respect to genetic nondiscrimination (found in § 146.121(b), § 146.121(c), § 146.121(e), § 146.122(b), § 146.122(c), § 146.122(d), and § 146.122(e)) do not apply to any group health plan (and group health insurance coverage) for any plan year, if on the first day of the pl…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026related by meaning
uter limits of the mandatory postponement period could be when a disaster declaration omits an ending date or is extended. Abdo, 162 T.C. at 169 n.13. The IRS disagrees with the Tax Court’s holding that the phrase “in the same manner” in former section 7508A(d) is unambiguous and will continue to defend its interpretat…
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’ …