IRCProposed Rules (FR)Proposed May 13, 2026
…is section (III.F.1-3) of this preamble.
Table 2—Affected Entities
Group Health Insurance Companies
373 Group Health Insurance Issuers
811
Group Health Plans and Sponsoring Employers
522,811
Participants and Eligible Employees 139
54,411,264
Participants and Eligible Employees Likely to Enroll
743,361
The
Departments s…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…7.2. TPAs and Issuers
The Department also estimates that the proposed rule will affect 205 TPAs and 373 issuers (
i.e.,
health insurance companies) in the group market with 809 issuers/State combinations [211]
IRCCourt RulingsMay 23, 1979related by meaning
…4 (1932). Furthermore, we believe the rule enunciated in U.S. Asiatic Co. v. Commissioner, 30 T.C. 1373 (1958), and Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), was correct. These cases produced the rule that corporate deductions were not allowable, with respect to compensat…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…reater detail later below.
Table 2—Affected Entities
Total
ERISA-Covered Group Health Plans
2,765,373
TPAs
205
Issuers in the group market
373
Issuers/state combinations in the group market
811
1. Group Health Plans, Participants, and Beneficiaries
The proposed rule would affect ERISA-covered group health plans. The …
IRCCourt RulingsFeb 25, 2014
…ment, indicating that she was enrolled in Micron's plan during 2008 and that
she had contributed $1,373 to Micron's plan. Petitioner also received from
Micron a pay stub indicating that she had contributed $1,373 to Micron's plan.5
5It is unclear from the record whether Micron matched petitioner's 2008
contribution wit…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
… by the inflation adjustment factor for 2010 of 1.08745, which resulted in a maximum penalty of $54,373. The amount of the increase from $50,000 to $54,373 is $4,373, which is less than the statutory cap of 150 percent of the existing $50,000 penalty, which is $75,000; accordingly, the amount of the increase is not lim…
IRCCourt RulingsJul 31, 2000
…lan paid the first-year premium, and, at the end of
that year, the conversion credit balance was $2,373.60 ($2,836.50
- $565.11 + $102.21); the $102.21 is the interest of 4.5 percent
earned on the conversion credit balance (($2,373.60 - $102.21) x
4.5% = $102.21)). None of the conversion credit balance could
have been …
IRCCourt RulingsDec 2, 1981related by meaning
of Claims, or the district court of the United States for the District of Columbia may make a declaration with respect to such initial qualification.” It is clear that Congress intended that the procedures under secs. 7476 and 7428 be similar. See S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 624-627); H. Rept. 94-658 (…
IRCCourt RulingsMay 20, 1976related by meaning
ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment.
SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
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…
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsJan 22, 2025
…ue Service (IRS or
respondent) determined a de ficiency in petitioner’s f ederal income tax of
$83, 373 and additions to tax pursuant to sections 6651(a)(1) and (2)
1
and
6654 of $8,566, $ 7,4 24 , and $ 1,071, respectively , for the 2018 taxable
year. The issues for decision are whether for 2018 petitioner is
(1) enti…
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…
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…
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 RulingsMar 25, 2013
…ioner reported gross receipts/sales of $65,954,366; gross
profit of $9,686,513; total income of $10,373,588; and taxable income of $41,948
IRCCourt RulingsJan 3, 2011
…tire $13 , 510. would
double count the cost of life insurarice protîction by an amount
equal to $2, 373 . ($23, 161 (or $13, 510 + $9, 657) minus. $20 , 7.93
(or Šl8, 000 + $2, 793) éqifals $2, 37 . ) Consequently, we deem the,
$2, 373 an amount al eady contributed by peti ioner for purposes
of such calcùlatri'on and, …
IRCCourt RulingsMay 27, 1968related by meaning
404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60.
All Code references herein are to the Internal Revenue Code of 1954.
Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
IRCCourt RulingsFeb 9, 2023
…igating positions. It is worth pointing
out that both positions incorporate an R&D offset of $4,117,373.
Additionally, petitioner’s position expressly accounts for, and
61