The assessable population included the participants in the microbiologically eligible population who met the criteria for favorable or unfavorable status with respect to the primary outcome.

However, when his daughter pays the $600,000 RAD on his behalf, his assessable assets increase by this full amount. The RAD value cannot be reduced by the debt owing to his daughter.

Section 6751(b) of the Code has been a potent weapon for taxpayers since the Second Circuit held in Chai that certain penalties are not valid without written managerial approval. See Chai v. Comm ...

ASSESSABLE PAYMENT RULES An applicable large employer that fails to offer minimum essential coverage or offers coverage that is unaffordable or does not provide minimum value may be liable for an ...