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53 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 85 FR 23172 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business
    IRCProposed Rules (FR)Proposed Apr 24, 2020
    ment activities should be treated as a separate unrelated trade or business for purposes of section 512(a)(6). Section 512(a)(1) ( printed page 23179) provides that UBTI means the gross income derived by an exempt organization from any unrelated trade or business regularly carried on by it. Further, section 512(a)(1) p…
  2. 85 FR 77952 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business
    IRCFinal Rules (FR)Dec 2, 2020
    …at the charitable contribution deduction could be taken against total UBTI calculated under section 512(a)(6)(B). Second, the structure of section 512(a)(6) itself confirms that Congress did not intend for any deductions to be taken against total UBTI calculated under section 512(a)(6)(B) other than the ones specifical…
  3. 115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner
    IRCCourt RulingsNov 9, 2000★ strong match
    …(A) for post-retirement medical bene- - 25 - fits). We find the Trustee’s interpretation of section 512(a)(3)(E)(i) (viz., the parenthetical phrase “(not taking into account any reserve described in section 419A(c)(2)(A) for postretirement medical benefits)” modifies both “an amount of assets set aside” and “the accoun…
  4. I.R.C. § 6652(l) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (l) (l) Failure to file return with respect to certain corporate transactions In the case of any failure to make a return required under section 6043(c) containing the information required by such section on the date prescribed therefor (determined with regard to any extension of time for filing), unless it is shown th…
  5. 29 C.F.R. § 2560.502c-2(j) — Civil penalties under section 502(c)(2).
    ERISARegulationsJan 1, 2017related by meaning
    (j) (j) Liability. (j)(1) (1) If more than one person is responsible as administrator for the failure to file the annual report, all such persons shall be jointly and severally liable with respect to such failure. (j)(2) (2) Any person against whom a civil penalty has been assessed under section 502(c)(2) pursuant to a…
  6. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …   See Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​05/​03/​provider-charges-relative-to-medicare-rates-2012-2018/​. Back to Citation 210…
  7. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses. In t…
  8. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016related by meaning
    herefore is not liable for any additions to tax. - 37 - [*37] petitioner is liable for the addition to tax under section 6651(a)(1) for 2004 and 2005. VI. Section 6651(a)(2) Addition to Tax Section 6651(a)(2) imposes an addition to tax on taxpayers for their failure to timely pay the amount of tax shown on a return. A …
  9. 89 FR 84079 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCFinal Rules (FR)Oct 21, 2024related by meaning
    t to withholding under subchapter A of chapter 3 (sections 1441 through 1446 of the Code). 1. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the regulation treats an Army Post Office (APO), a Fleet Post Office (FPO), or a Diplomatic Post Office (DPO) [2] address as an a…
  10. I.R.C. § 3405(e)(12) — Special rules for pensions, annuities, and certain other deferred income
    IRCCode / StatuteJan 12, 2018related by meaning
    (e)(12) (12) Failure to provide correct TIN If— no election under subsection (a)(2) or (b)(2) shall be treated as in effect and subsection (a)(4) shall not apply to such payee. (e)(12)(A) (A) a payee fails to furnish his TIN to the payor in the manner required by the Secretary, or (e)(12)(B) (B) the Secretary notifies …
  11. 84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
    persede the guidance in Notice 87-7 for payors of designated distributions with respect to their duty to withhold under sections 3405(a)(1) or (b)(1). A. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the proposed regulation treats an APO, FPO, or DPO address as an addr…
  12. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015related by meaning
    n October 13, 2011, petitioner's wife sent a final letter to Settlement Officer Owyhng informing him that petitioner had received his October 6, 2011, letter, and that petitioner had requested an extension of time on September 26, -7- [*7] 2011. The letter also reiterated that petitioner had no access to a computer and…
  13. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026related by meaning
    * PART 2560—RULES AND REGULATIONS FOR ADMINISTRATION AND ENFORCEMENT 4. The authority citation for part 2560 continues to read as follows: Authority: 29 U.S.C. 1132, 1135, and Secretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012). Section 2560.503-1 also issued under 29 U.S.C. 1133. Section 2560.502c-7 also iss…
  14. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ds of thousands of dollars in DISC commissions each year from a well-established business, and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount. -28IV. Section 6662(a) Penalty Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
  15. 75 FR 8796 — Civil Penalties Under ERISA Section 502(c)(8)
    ERISAFinal Rules (FR)Feb 26, 2010related by meaning
    it plans, and as such have no implications for the States or the relationship or distribution of power between the national government and the States. ( printed page 8800) List of Subjects 29 CFR Part 2560 Employee benefit plans Employee Retirement Income Security Act Law enforcement Pensions 29 CFR Part 2570 Administr…
  16. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    T,.C.. 200, 205 (20 06) , af f d. 521 F . 3d 128 9 (10th Cir . - 2008) ; Rogers v . Commi sioner, T.C. Memo. 2001-20, affd. without published opinion 281 F.3d 1278 (5th Cir. 2001) . Additionally, the Commissioner is not r uired to lay out the afactual basis for his determination in the notice of deficiency Ocmulgee" F…
  17. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    rmed in the employ of the United States further requires that the service be covered by a retirement system established by a law of the United States. We note that amendments made to the employment tax provisions subsequent to the years in issue have been interpreted in a manner inconsistent with our holding. See sec. …
  18. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    re to pay his 2004 taxes; and (4) whether the Court should impose a penalty under section 6673 for petitioner's advancement of frivolous or groundless arguments in proceedings instituted primarily for protest or delay. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of the par…
  19. 75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Jun 16, 2010related by meaning
    URE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * *. Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows: § 301.6404-0 Table of Contents. * * * * * § 301.6404-4 Suspension of interest and c…
  20. T.C. Memo. 2026-33 — Jonathan D. Sawyer v. Commissioner
    IRCCourt RulingsApr 16, 2026related by meaning
    nd remanding T.C. Memo. 1990-68, or demonstrate that the taxpayer actually received income, Edwards v. Commissioner, 680 F.2d 1268, 1270– 71 (9th Cir. 1982) (per curiam). Information supplied to the IRS by the taxpayer’s employer on Form W – 2, Wage and Tax Statement, or by other payors on Forms 1099, is sufficient to …