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…
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]
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…
80 FR 22004 — Proposed Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Em… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
DC, this 14th day of April, 2015.
Phyllis C. Borzi,
Assistant Secretary, Employee Benefits Security Administration, Department of Labor.
Footnotes
1. Code section 4975(c)(2) authorizes the Secretary of the Treasury to grant exemptions from the parallel prohibited transaction provisions of the Code. Reorganization Pla…
IRCCourt RulingsSep 30, 1991related by meaning
eems that sale to be a prohibited transaction for purposes of the section 4975(a) excise tax which is not excused by any applicable exception.
OPINION Section 4975, as added to the Internal Revenue Code by Title II of the Employee Retirement Income Security Act of 1974. imposes an excise tax on prohibited transactions.…
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 RulingsJan 27, 1998related by meaning
) and (b) of section 4975.
Section 4975 was added to the Internal Revenue Code by title
II of ERISA. ERISA sec. 2003(a), 88 Stat. 971. Section 4975(a) and (b) imposes a two-tier excise tax on prohibited transactions.
The policy behind the enactment of section 4975 was to tax
disqualified persons who engage in self-deal…
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 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 9, 1985related by meaning
erest) on the dates shown was as follows:
Bate Balance
8/31/78 $123,727.08
8/31/79 131,211.18
8/31/80 141,708.07
8/31/81 144,502.33
4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
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 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 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 RulingsFeb 9, 2023
…igating positions. It is worth pointing
out that both positions incorporate an R&D offset of $4,117,373.
Additionally, petitioner’s position expressly accounts for, and
61
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
… recommendations.”)
Back to Citation
221.
The commenter cited the
Chamber
opinion, 885 F.3d at 372-373, as support for the assertion that financial professionals receive “no compensation” for the provision of advice that is incidental to brokerage services. On page 373, the
Chamber
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
…n
(hours)
Total estimated
labor cost
($)
2022
326
326
48
15,638
$1,603,770.05
2023
326
326
12
3,910
373,158.29
2024
326
326
12
3,910
373,158.29
Three-year average
326
326
24
7,819
783,362
E. ICRs Regarding Air Ambulance Reporting Requirements for Providers of Air Ambulance Services (45 CFR 149.460)