Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 28
Page 224
... group contracts did not constitute a contract - by - con- tract valuation , did not establish a credible discrete value for each contract , and is otherwise deficient , claimed loss deduc- tions under sec . 165 , I.R.C. , in the ...
... group contracts did not constitute a contract - by - con- tract valuation , did not establish a credible discrete value for each contract , and is otherwise deficient , claimed loss deduc- tions under sec . 165 , I.R.C. , in the ...
Page 225
... group contracts ( group con- tracts ) . Unless otherwise indicated , all section references are to the Internal Revenue Code in effect for 1994 , and all Rule ref- erences are to the Tax Court Rules of Practice and Proce- dure ...
... group contracts ( group con- tracts ) . Unless otherwise indicated , all section references are to the Internal Revenue Code in effect for 1994 , and all Rule ref- erences are to the Tax Court Rules of Practice and Proce- dure ...
Page 226
... group contracts.1 Generally , sponsoring organizations for each group con- tract , such as employers , as well as the individual members of each group were to pay premiums to petitioner , and peti- tioner was to provide health insurance ...
... group contracts.1 Generally , sponsoring organizations for each group con- tract , such as employers , as well as the individual members of each group were to pay premiums to petitioner , and peti- tioner was to provide health insurance ...
Page 227
... group contract were based on one of three premium rating methods . Community - Rated Group Contracts Premiums relating to groups consisting of fewer than 100 individual members ( representing approximately 90 percent of all of petitioner's ...
... group contract were based on one of three premium rating methods . Community - Rated Group Contracts Premiums relating to groups consisting of fewer than 100 individual members ( representing approximately 90 percent of all of petitioner's ...
Page 228
... group contracts would be the same for all community - rated group contracts with the same bene- fit and the same coverage type . Experience- and Cost - Plus - Rated Group Contracts Premiums petitioner charged relating to groups with 100 ...
... group contracts would be the same for all community - rated group contracts with the same bene- fit and the same coverage type . Experience- and Cost - Plus - Rated Group Contracts Premiums petitioner charged relating to groups with 100 ...
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abuse of discretion administrative costs affd allocable to medical amended amortization Appeals Office apply assessed bankruptcy basis carryback challenge Charles Schwab Corp claimed Commis Commissioner Commissioner's Congress corporation Court of Appeals customer accounts decision election entitled Federal income tax franchise tax Grigoraci Income Tax Regs income tax return intangible assets Interest Interest Internal Revenue Internal Revenue Code Internal Revenue Service issue judicial review jurisdiction legislative history levy loss deductions ment monthly service fees noncontract patient fees notice of deficiency notice of determination offer in compromise overpayment interest paid parties payment percentage method peti petition petitioner petitioner's expert procedures proceeding provides pursuant qualified offer refund relief from joint relief under section respect Respondent argues Rose's Rule sioner statutory summary judgment supra T.C. Memo Tax Court tax lien taxable taxpayer tion trial de novo underlying tax liability valuation Village West Wiwi