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77 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac…
    IRCProposed Rules (FR)Proposed Jul 12, 2023
    … to strike the last sentence in 26 CFR 54.9831-1(c)(4)(i), 29 CFR 2590.732(c)(4)(i), and 45 CFR 146.145(b)(4)(i), in order to consolidate the requirements that are specific to hospital indemnity or other fixed indemnity insurance to qualify as an excepted benefit in a new proposed 26 CFR 54.9831-1(c)(4)(ii)(D), 29 CFR …
  2. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    R 2590.732 and proposed paragraph (b)(3)(i) of 45 CFR 146.145, fertility benefits would be excepted benefits if they satisfy the ( printed page 27145) requirements of proposed paragraph (c)(3)(ix) of 26 CFR 54.9831-1 and 29 CFR 2590.732 and proposed paragraph (b)(3)(ix) of 45 CFR 146.145. Under proposed paragraph (c)(3…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
  4. 90 FR 2645 — Catch-Up Contributions
    IRCProposed Rules (FR)Proposed Jan 13, 2025
    …ar from the employer sponsoring the plan (as defined in proposed § 1.414(v)-2(b)(3)) that exceeded $145,000, then section 414(v)(1) would apply with respect to the participant's elective deferrals that are catch-up contributions only if they are designated Roth contributions (as defined in section 402A(c)(1)). Under pr…
  5. 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…
  6. 79 FR 59130 — Amendments to Excepted Benefits
    IRCFinal Rules (FR)Oct 1, 2014
    …ng EAPs were proposed in paragraph (c)(3)(vii) of 26 CFR 54.9831-1, 29 CFR 2590.732, and 45 CFR 146.145. However, HHS regulations published on October 30, 2013 and effective December 30, 2013 redesignated 45 CFR 146.145(c) as paragraph (b) (78 FR at 65092). Additionally, because these regulations are finalizing only th…
  7. T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov…
    IRCTreasury DecisionsOct 6, 2014
    …to services performed by O in L’s taxable years as follows: $55,000 ($50,000 + $5,000) to 2018 and $145,000 ($125,000 + $20,000) to 2019. (v) The portion of the DDR attributed to a disqualified taxable year under paragraph (d) of this section that exceeds the deduction limit for that disqualified taxable year, as reduc…
  8. T.C. Memo. 1996-224 — Richard L. & Marjorie A. Freese v. Commissioner
    IRCCourt RulingsMay 16, 1996
    …compensation be withheld by the employer for contribution to a retirement plan. Ohio Rev. Code Sec. 145.01 and 145.47 (Baldwin 1996). Under section 145.03 of the Ohio Revised Code, membership 3 in PERS is compulsory upon being employed, with some exceptions not relevant herein. During 1990, an aggregate of $133.88 was …
  9. 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…
  10. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
  11. 78 FR 77632 — Amendments to Excepted Benefits
    IRCProposed Rules (FR)Proposed Dec 24, 2013
    …ce coverage). Back to Citation 11.  26 CFR 54.9831-1(c)(3)(v); 29 CFR 2590.732(c)(3)(v); 45 CFR 146.145(c)(3)(v). Back to Citation 12.  26 CFR 54.9831-1(c)(4); 29 CFR 2590.732(c)(4); 45 CFR 146.145(c)(4). See also Q7 in FAQs about Affordable Care Act Implementation Part XI, available at http://www.dol.gov/​ebsa/​faqs/​…
  12. 83 FR 54420 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans
    IRCProposed Rules (FR)Proposed Oct 29, 2018
    …nue to apply. Back to Citation 90.  26 CFR 54.9831-1(c)(3)(v); 29 CFR 2590.732(c)(3)(v); 45 CFR 146.145(b)(3)(v). Back to Citation 91.   See section 125(i) of the Code. Back to Citation 92.  26 CFR 54.9831-1(c)(3)(vii); 29 CFR 2590.732(c)(3)(vii); 45 CFR 146.145(b)(3)(vii). Back to Citation 93.   See 26 CFR 54.9831-1(c…
  13. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    ses of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2016. Rev. Proc. 2016–16 Rev. Proc. 2016–16 General Rules and Specifications for Substitute Form 941, Schedule B (Form 941), Schedule D (Form 941), and Schedule R (Form 941) This procedure provides general rules a…
  14. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
  15. Treas. Reg. § 1.501(h)-3(e) — Lobbying or grass roots expenditures normally in excess of ceiling amount.
    IRCRegulationsJul 12, 2016
    …+ 15% of $200,000=) 130,000 120,000 32,500 30,000 1980 800,000 (20% of $500,000 + 15% of $300,000=) 145,000 100,000 36,250 60,000 1981 800,000 (20% of $500,000 + 15% of $300,000=) 145,000 100,000 36,250 65,000 1982 900,000 (20% of $500,000 + 15% of $400,000=) 160,000 150,000 40,000 65,000 Total 3,200,000 580,000 470,00…
  16. 90 FR 44527 — Catch-Up Contributions
    IRCFinal Rules (FR)Sep 16, 2025
    …Thus, under the proposed regulations, a catch-up eligible participant who had FICA wages exceeding $145,000 (as adjusted) in the preceding calendar year from any employer other than the employer sponsoring the plan (as defined with respect to the participant in accordance with proposed § 1.414(v)-2(b)(3)) would not be …
  17. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    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…
  18. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
  19. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    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…
  20. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    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 …