Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
2, 513, and 514.—See section 3.01(78), above.
(83) Section 529.—Qualified Tuition Programs.—Whether a state-run tuition program qualifies under § 529. (84) Sections 542, 543, and 544.—Definition of Personal Holding Company; Personal Holding Company Income; Rules for Determining Stock Ownership.—Whether the application …
IRCCourt RulingsFeb 9, 2023
…ny substantive rule (other than one granting or recognizing
85
Codified as amended at 5 U.S.C. sec. 553 (2018).
86
Codified as amended at 5 U.S.C. sec. 553(b).
87
Codified as amended at 5 U.S.C. sec. 553(b).
88
Codified as amended at 5 U.S.C. sec. 553(c).
89
Codified as amended at 5 U.S.C. sec. 553(d).
107
exemption or…
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
… and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021★ strong match
…
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…
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…
91 FR 55462 — Federal Independent Dispute Resolution Operations; Correction IRCFinal Rules (FR)Aug 28, 2026
exceptions from the APA notice and comment and delay in effective date requirements. Section 553(b)(B) of the APA authorizes an
( printed page 55464) agency to dispense with normal notice and comment rulemaking procedures for good cause if the agency makes a finding that the notice and comment process is impracticable…
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
IRCCourt RulingsJan 2, 2020related by meaning
principles and to deter the waste of judicial resources. See Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwiler v. Commissioner, T.C. Memo. 2016-18, at *10. The Court has provided ample warnings to petitioners of
the potential implications of continuing to assert frivolous and groundless
arguments. For…
ERISAFinal Rules (FR)May 18, 2023
…osed rule in the
Federal Register
before the provisions of a rule take effect. In addition, section 553(d) of
( printed page 31610) the APA mandates a 30-day delay in effective date after issuance or publication of a substantive rule. Sections 553(b)(3)(B) and 553(d)(3) of the APA provide for exceptions from the APA no…
IRCCourt RulingsOct 19, 2010related by meaning
ions, this Court concludes that a
section 6673 penalty of $500 is appropriate. It is
"inappropriate that taxpayers who promptly pay their taxes should have the cost of Government and tax collection improperly
increased by citizens apparently unwilling to obey the law or
shoulder their assigned share of the Government c…
89 FR 3352 — Collateral Acceptability and Valuation IRCFinal Rules (FR)Jan 18, 2024
…lic comment and without the 30-day delayed effective date ordinarily prescribed by the APA 5 U.S.C. 553(b) and (d). Pursuant to section 553(b)(B) of the APA, general notice and the opportunity for public comment are not required with respect to a rulemaking when an “agency for good cause finds (and incorporates the fin…
IRCCourt RulingsJan 12, 1998related by meaning
tely $1,026,855 in U. S.
currency deposited into various bank accounts during the period
January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts
alleging violations of customs reporting requirements.
On January 9, 1992, petitioner entered into a plea a…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
is obtained on or before the date the IRS issues a notice of
deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74
…
IRCCourt RulingsDec 28, 2000related by meaning
filed a voluntary petition
for reorganization under chapter 11 of the Bankruptcy Code (the
bankruptcy case). In the bankruptcy case, the Commissioner asserted a section 4971 deficiency against the company for
- 4 -
failure to satisfy the minimum funding standard pursuant to
section 412.
In 1994, petitioner was indicte…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
separate
arguments. First, respondent argues that “[b]y the plain language of”
section 6662, the adequate disclosure exception does not apply to gross and substantial valuation misstatement penalties. Second, respondent
argues that even if his first argument is incorrect, no adequate
disclosure relief can be granted be…
89 FR 4547 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges; Correction IRCFinal Rules (FR)Jan 24, 2024
…e effective no sooner than 30 days after the date of publication in the
Federal Register . Sections 553(b)(B) and 553(d)(3) of the APA provide for exceptions from the APA notice and comment and delay in effective date requirements. Section 553(b)(B) of the APA authorizes an agency to dispense with normal notice and com…
IRCCourt RulingsFeb 25, 2016related by meaning
ed for Forms 5329. Petitioner once again does not argue that his
- 38 -
[*38] failure to timely pay was due to reasonable cause and not due to willful neglect. Accordingly, petitioner is liable for the addition to tax under section
6651(a)(2) for 2004 and 2005.
VII. Section 6662A Penalty
Section 6662A provides: "If a t…
85 FR 40589 — Conflict of Interest Rule-Retirement Investment Advice: Notice of Court Vacatur ERISAFinal Rules (FR)Jul 7, 2020
…lized.[3]
EBSA's website will reflect all of these changes.[4]
Procedural and Other Matters Section 553 of the Administrative Procedure Act, 5 U.S.C. 553(b)(3)(B), provides that when an agency for good cause finds that notice and public procedures are impracticable, unnecessary or contrary to the public interest, the a…
IRCCourt RulingsJul 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
IRCCourt RulingsJul 31, 2000
…e end of that year, the
conversion credit balance was $12,844.23 ($6,236.30 + $7,720 -
$1,665.17 + $553.10); the $553.10 is the interest of 4.5 percent
earned on the conversion credit balance (($12,844.23 - $553.10) x
4.5% = $553.10)). Of the conversion credit balance, $6,101.01
could have been transferred at this time…