88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
…al/surgical benefits covered by the plan or coverage, as further provided in this section and § 146.137. Accordingly, in complying with the provisions of PHS Act section 2726, this section, and § 146.137, plans and issuers must not design or apply financial requirements and treatment limitations that impose a greater b…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…d by the plan or coverage in the same classification, as further provided in this section and § 146.137. Accordingly, in complying with the provisions of PHS Act section 2726, this section, and § 146.137, plans and issuers must not design or apply financial requirements and treatment limitations that impose a greater b…
IRCCourt RulingsJul 14, 2005related by meaning
er for calendar year
1993 except that the reference to "20% reduction" was changed to
"50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA
1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this
connection, prior to its amendment by OBRA …
IRCCourt RulingsNov 5, 1999
…ar
End of year
Cash $646 $2,295
Receivables 38,922 40,063
Investments
Real estate and mortgages -0- 137,270
Loans to participants:
Mortgages -0- -0Other 152,112
-0-
Total investments 152,112
137,270
Total assets 191,680 179,628
Liabilities
Total liabilities -0-
-0-
Net assets 191,680 179,628
The Form 5500 also reports …
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…mplying with paragraph (n) in §1.125-5. (2) Additional requirements under sections 105(h), 129, and 137. A written plan is required for self-insured medical reimbursement plans (§1.105-11(b)(1)(i)), dependent care assistance programs (section 129(d)(1)), and adoption assistance (section 137(c)). Any of these plans or p…
110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
w why the statute as
enacted contains language different from that in the House and
- 10 -
1
We have been unable to find any other section of the Code that uses this phrase. Other sections of the Code that authorize
this Court to grant a declaratory judgment include secs. 6234,
7428, 7477, 7478, and 7479.
2
Sec. 7503 a…
IRCCourt RulingsApr 2, 2020
…........... 136 DD. Intermediary period: January 1 1-12, 2011 . . . . . . . . . . . . . . . . . . . 137
EE. Period 19: January 13 through February 15, 201 1 . . . . . . . . . . . . . 137
1. Introduction...................................... 137
2. Events .......................................... 138
3. Analysis and ho…
IRCCourt RulingsOct 1, 2025related by meaning
lli v.
Commissioner, 129 T.C. 107, 111 (2007); Murphy v. Commissioner, 125
T.C. 301, 308, 320 (2005) , aff’d , 469 F.3d 27 (1st Cir. 2006) . Where the underlying tax liability was properly at issue in the CDP hearing, we
will review the determination de novo. Lunsford v. Commissioner, 117
T.C. 183, 185 (2001) (citing G…
IRCCourt RulingsJan 17, 2024★ strong match
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…
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
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCCourt RulingsJul 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…additional documentation, but for purposes of this burden analysis assume that half of claimants (6,137) do. The Departments assume that the IRO has clerical staff with a labor rate of $55.23 that will spend, on average 5 minutes per claimant preparing and forwarding the required documents, and that IROs incur an avera…
IRCCourt RulingsAug 30, 1999related by meaning
in effect ordered him to
satisfy the increased amount awarded to Ms. Czepiel by making the
IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately
$33,000 on deposit in his IRA's. Respondent counters that the
divorce judgment is not a QDRO and that petition…
T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov… IRCTreasury DecisionsAug 15, 2016related by meaning
ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred.
EMPLOYEE PLANS
T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
IRCCourt RulingsSep 23, 2019
…is was CAD186,000, which,
according to the conversion rate (0.73921) used by both parties, equaled $137,493
at the time of purchase. Because of this inconsistency, petitioner husband's
testimony on this point was not credible. Without documentary evidence or
credible testimony supporting their claim, petitioners have n…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
IRCCourt RulingsFeb 24, 2016
…transferred the funds between his accounts and eventually
¹²Ancira v. Commissioner, 119 T.C. at 136-137.
¹³Ancira v. Commissioner, 119 T.C. at 137-139.
¹4Ancira v. Commissioner, 119 T.C. at 137.
- 16 -
[*16] to Mr. Carver. These actions show that he had unfettered control over the
funds. Accordingly, he was not acting …
IRCCourt RulingsMar 31, 2015related by meaning
Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the
IRM provision that addresses the Commissioner's ability to levy upon retirement
accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330
hearing request and provided documents supporting this claim. Settlement Officer
Degiovanni …