85 FR 81097 — Grandfathered Group Health Plans and Grandfathered Group Health Insurance Coverage IRCFinal Rules (FR)Dec 15, 2020
… paragraph (g)(4)(i), the increase in the overall medical care component is computed by subtracting 387.142 (the overall medical care component of the CPI-U (unadjusted) published by the Department of Labor for March 2010, using the 1982-1984 base of 100) from the index amount for any month in the 12 months before the …
85 FR 42782 — Grandfathered Group Health Plans and Grandfathered Group Health Insurance Coverage IRCProposed Rules (FR)Proposed Jul 15, 2020
…00. For this purpose, the increase in the overall medical care component is computed by subtracting 387.142 (the overall medical care component of the CPI-U (unadjusted) published by the Department of Labor for March 2010, using the 1982-1984 base of 100) from the index amount for any month in the 12 months before the …
80 FR 72192 — Final Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, Dependent Coverage, Appeals, and Patient Protec… IRCFinal Rules (FR)Nov 18, 2015
…00. For this purpose, the increase in the overall medical care component is computed by subtracting 387.142 (the overall medical care component of the CPI-U (unadjusted) published by the Department of Labor for March 2010, using the 1982-1984 base of 100) from the index amount for any month in the 12 months before the …
T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003related by meaning
only to the extent that the amount exceeds the amount the participant included in gross income when he or she obtained a vested right to the benefit. 7. Severance Pay and Other Exceptions
75 FR 34538 — Interim Final Rules for Group Health Plans and Health Insurance Coverage Relating to Status as a Grandfathered Health Plan Under the Patient Protection and Aff… IRCFinal Rules (FR)Jun 17, 2010
…00. For this purpose, the increase in the overall medical care component is computed by subtracting 387.142 (the overall medical care component of the CPI-U (unadjusted) published by the Department of Labor for March 2010, using the 1982-1984 base of 100) from the index amount for any month in the 12 months before the …
IRCRegulationsJan 14, 2021
…edical inflation (as defined in paragraph (g)(4)(i) of this section) from March 2010 is 0.2269 (475−387.142 = 87.858; 87.858 ÷ 387.142 = 0.2269). The maximum percentage increase permitted is 37.69% (0.2269 = 22.69%; 22.69% + 15% = 37.69%). Because 33.33% does not exceed 37.69%, the change in the copayment requirement a…
IRCCourt RulingsApr 26, 2005related by meaning
t, as follows:
(a) General: Disposition of an action for
declaratory judgment which involves the initial
qualification of a retirement plan * * * will ordinarily be made on the basis of the administrative
record, as defined in Rule 210(b)(12). Only with the
permission of the Court, upon good cause shown, will
any party…
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 RulingsFeb 9, 2023
… a licensing
agreement regarding such payments. Computation of the $4,283,153
amount starts with $9,387,909, an amount that does not account for the
Brazilian restriction that, if a product is covered by a patent license or
by a technology-transfer agreement between a Brazilian company and
its controlling foreign compa…
IRCCourt RulingsFeb 25, 2010
…1974 ) ; Ewens & Miller , Inc . v . Commissioner , supra at
270 ; Weber v . Commissioner , supra at 387 . We cgnsider all of the
facts and circumstances of each case, and no single factor i s
determinative . Ewens & Miller, Inc . v . Commissioner , supra a t
270 ; Weber v . Commissioner , supra at 387 .
Although not th…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…isclosure would take a clerical worker, on average, five minutes, resulting in an hour burden of 15,387 hours with an equivalent cost of $976,301.[47]
( printed page 75996)
Table 8—Hour Burden and Equivalent Cost Associated Preparing and Sending Disclosures
Year 1
Subsequent years
Activity
Burden hours
Equivalent
bur…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
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 (…
50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner IRCCourt RulingsMay 29, 1968related by meaning
-10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
IRCCourt RulingsMay 20, 1976related by meaning
es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
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 RulingsAug 1, 1996related by meaning
7 (1987); Hays Corp. v.
Commissioner
, 40 T.C. 436 (1963), affd. 331 F.2d 422 (7th Cir.
1964); see sec. 7442. The Court has no authority to disregard the express provisions of statutes adopted by Congress, even
where the result in a particular case seems harsh. See, e.g.,
Estate of Cowser v. Commissioner
, 736 F.2d 116…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
…for disclosures provided prior to enrollment, including printing costs, would be approximately $712,387.
Table 2—Proposed Annual Ongoing Costs Regarding Disclosure of Agent and Broker Compensation to Enrollees Prior to Enrollment
Respondent
Estimated number of respondents
Estimated number of responses
Estimated burden
…
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 RulingsJul 3, 1974related by meaning
nt of benefits was related to years of service, and the receipt of benefits by the employee would not begin until after termination of his employment. Although the facts in New York Seven-Up are distinguishable from those in the present case, this Court made the statement in New York Seven-Up that section 404(a) is not…