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1. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsFeb 28, 2024
   ur decision beco mes final. In these cases, therefore, section 6501( l )(4) does not retroactively prevent the Commissioner from making an assessment. Put another way, for notices of deficiency issued on or after December 29, 2022, the Commissioner must take into account the provisions of section 6501(l )(4) in determi…
2. 88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents
   IRCFinal Rules (FR)Feb 23, 2023
   …, 1.6037-2(b), 1.6045-2(i), 1.6045-4(s), 1.6050I-1(h), 1.6050I-2(f), 1.6050M-1(f)(4), 54.6011-3(f), 301.1474-1(e), 301.6011-2(g)(1), 301.6011-3(f), 301.6011-5(f), 301.6011-11(e), 301.6011-12(f), 301.6011-13(f), 301.6011-14(f), 301.6011-15(f), 301.6012-2(f), 301.6037-2(f), and 301.6721-1(h) provide that the new provisio…
3. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
   IRCCourt RulingsAug 13, 1990
   …the year in which the act * * * giving rise to liability for such tax occurred.” Similarly, section 301.6501(n)-1(a), Proced. & Admin. Regs., provides that for purposes of section 6501, the return of a plan or trust “with respect to any act giving rise to a tax imposed by * * * section 4975” shall be considered to be t…
4. 87 FR 50240 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations
   IRCFinal Rules (FR)Aug 16, 2022★ strong match
   …ns in the Treasury Department and the IRS participated in their development. List of Subjects in 26 CFR Part 301 Employment taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, 26 CFR part 301 is amended as foll…
5. Rev. Rul. 2003-88 — Section 4971; running of statute of limitations; and filing of form. This ruling states that the filing of a Form 5330, and not the filing of a Form 5500, star…
   IRCRevenue RulingsAug 11, 2003
   tion of that period. Section 6501(a) further provides that, for this purpose, the term “return” means the return required to be filed by the taxpayer. However, there are exceptions to the three year rule in § 6501(a). Section 6501(e)(3) provides that, except as otherwise provided in § 6501(c), in the case of a return o…
6. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
   IRCProposed Rules (FR)Proposed Jul 23, 2021
   …graphs, the economic impact is not significant. Under section 6011(e) of the Code and §§ 1.6050M-1, 301.6011-2, 301.6011-3, 301.6011-5, 301.6037-2, 301.6057-3, 301.6058-2, and 301.6059-2, filers are already required to file returns and statements electronically if, during a calendar year, they are required to file 250 …
7. 29 C.F.R. § 2520.101-4 — [Reserved]
   ERISARegulationsJan 1, 2017related by meaning
   [Reserved]
8. 29 C.F.R. § 2520.102-1 — [Reserved]
   ERISARegulationsJan 1, 2017related by meaning
   [Reserved]
9. 29 C.F.R. § 2520.104-45 — [Reserved]
   ERISARegulationsJan 1, 2017related by meaning
   [Reserved]
10. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011
    …sen of the Office of Associate Chief Counsel (Procedure and Administration). List of Subjects in 26 CFR Part 301 Income taxes Penalties Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, 26 CFR part 301 is amended as follows: ( printed page 52261) PART 301—PROCEDURE AND ADMI…
11. 29 C.F.R. § 2520.104-28 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
12. 29 C.F.R. § 2520.104a-7 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
13. 29 C.F.R. § 4907.131-4907.139 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
14. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014
    …The running of any applicable period of limitations is not suspended for the period during which a §301.9100–1 request has been filed. See §301.9100–3(d)(2). If the period of limitations on an assessment under §6501(a) for the taxable year in which an election should have been made, or any taxable year that would have …
15. 29 C.F.R. § 2530.205 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
16. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013
    …he running of any applicable period of limitations is not suspended for the period during which a § 301.9100-1 request has been filed. See § 301.9100-3(d)(2). If the period of limitations on an assessment under § 6501(a) for the taxable year in which an election should have been made, or any taxable year that would hav…
17. 29 C.F.R. § 2530.207-2530.209 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
18. 29 C.F.R. § 4907.141-4907.148 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
19. 102 T.C. 499; 102 T.C. No. 17 — Janpol v. Commissioner
    IRCCourt RulingsMar 28, 1994
    …1120 returns as required by the regulations. Id. at 795. Subsection (1)(1) (then (n)(l)) of section 6501 was added to the Code by the Tax Reform Act of 1969, Pub. L. 91-172, sec. 101(g)(1), 83 Stat. 525. Thus, Congress enacted section 6501(1)(1) after publication of Knollwood Memorial Gardens v. Commissioner, supra, an…
20. 29 C.F.R. § 4907.161-4907.169 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]