89 FR 85750 — Enhancing Coverage of Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Oct 28, 2024
…mber of respondents
Number of responses
Burden hours per respondent
Total burden hours
Total cost
1,672
1,672
135
225,720
$35,089,261
In addition to the one-time cost and hour burden estimated above, issuers and TPAs would incur ongoing annual costs for website maintenance, programming updates, and updates to the list …
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…
193.15
2,084,668
−2,084,668 Primary Assumption
21,586
1
193.15
4,169,336
0
21,586
2
193.15
8,338,672
4,169,336
21,586
3
193.15
12,508,008
8,338,672
3. Initial Notice of Default E-Delivery and Right to Opt Out:
A. Compensation and Benefits Manager prepares initial notice of default e-delivery and right to opt out (…
IRCCourt RulingsSep 24, 2007related by meaning
moot, or irrelevant .
To reflect the foregoing,
Decision will be entere d
for respondent .
8Sec . 6654(e) provides two exceptions to the sec . 6654(a) addition to tax . First, the addition is not applicable if the
tax shown on the taxpayer's return for the year in question (or,
if no return is filed, the taxpayer's tax…
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 RulingsNov 7, 1996★ strong match
… petitioner's Federal excise tax under section 4980A
for the taxable year 1991 in the amount of $26,672.
2
The issue for decision is whether the Transfer Refund
distribution received by petitioner in 1991 from the Maryland
IRCCourt RulingsJul 31, 2000★ strong match
… of $187,827. At the time of conversion, the Cgroup term policy’s conversion credit balance was $78,672.63, and
- 45 -
$74,739 of that amount ($78,672.63 x 95%) was transferred to the
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 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…o Citation
272.
The burden is estimated as follows: 245,336 health care facilities × 2 hours = 490,672 hours. A labor rate of $140.96 is used for a lawyer. The labor rate is applied in the following calculation: 245,336 health care facilities × 2 hours × $140.96 = $69,165,125. 245,336 health care facilities × 2 hours …
IRCCourt RulingsJun 29, 2015
…series of
agreements. Pursuant to these agreements the Summa subsidiaries paid JC Export
$129,791, $672,048, $625,438, and $810,646 on January 18, April 23, July 25,
- 7 -
[*7] and December 22, 2008, respectively.5 Summa also paid $1,083 of expenses
on behalf of JC Export and JC Holding during 2008. The Summa subsidiar…
IRCCourt RulingsFeb 18, 1997related by meaning
ioner's retirement distribution's
being taxed twice. We think petitioners' contention is
meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended
by Congress. E.g., Maass v. Higgins
, 312 U.S. 443, 449 (1941);
United States v. Supplee-Biddle Hardware …
IRCCourt RulingsJan 13, 1997related by meaning
7,676 represents the imposition of
additional tax under section 72(t) on petitioner's premature
retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of
proof on this issue. Rule 142(a). However, the parties
stipulated that $20,655.42 of that distribution …
IRCCourt RulingsSep 23, 2019related by meaning
or the taxing
authority that imposed the levy. Petitioners have not shown that they are eligible
for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a
loan which they used to purchase a home in Vermont in 2013. Petitioners
provided only Form 1099-…
IRCCourt RulingsFeb 28, 2024related by meaning
e was “intertwined with the merits,” i.e., with the
question of whether petitioner had actually made “excess contributions”
reportable on Form 5329.
5 On August 27, 2021, petitioner filed a second Motion for Summary Judgment, contending that the IRS “is precluded as a matter of
law from asserting excise tax liability u…
IRCCourt RulingsMay 23, 1996
… on this item. The
parties stipulated that the proper amount of the adjustment
should have been $10,672.
years in issue, petitioners listed the "taxable amount" of such
items as $18,039, $21,923, and $23,169, respectively. In
computing the amounts reported on line 17b, petitioners reduced
the amounts shown on line 17a …
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
IRCCourt RulingsJan 2, 2020related by meaning
pute.5
3Respondent determined some itemized deductions should be disallowed
subject to the sec. 68 limitation and a claimed child tax credit should be disallowed under sec. 151(d).
4The sec. 6662(a) penalties for remaining years 2008, 2009, 2010, 2012,
2013, and 2014 stem solely from the disallowed NOL carried forward …
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsDec 24, 1985
…tor. Sec. 1.677(a)-l(d), Income Tax Regs.
In the present case, trustee was a nonadverse party. Sec. 672(a), (b); sec. 1.672(a)-l, (b)-l, Income Tax Regs. Moreover, trust funds (including income) may be used to satisfy asmg’s legal obligation on malpractice claims resulting from acts of asmg’s employees. This case does …
PLR 200226012 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsJun 28, 2002
…ative will
not be Taxpayer or any person related or subordinate to Taxpayer within the meaning
of § 672(c)(2). At her death, Taxpayer may designate a successor special
representative in her will. The charter further provides that any common stock of
Corporation held by Foundation may only be sold pursuant to a resoluti…