IRCCourt RulingsApr 2, 2020
…the Tax Court becomes final. Secs. 6212(a),
6213(a). Underpayment interest, provided for by section 6601, "shall be assessed,
collected, and paid in the same manner as taxes." Sec. 6601(e)(1). Therefore, the
collection of interest can only follow an assessment of interest. Secs. 6502(a),
6601(g). Under section 6502(a)(…
I.R.C. § 6652(k) — Failure to file certain information returns, registration statements, etc. IRCCode / StatuteJan 24, 2020related by meaning
(k) (k) 1 Failure to make reports required under section 1202 In the case of a failure to make a report required under section 1202(d)(1)(C) which contains the information required by such section on the date prescribed therefor (determined with regard to any extension of time for filing), there shall be paid (on notic…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
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…
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
IRCCourt RulingsJan 17, 2024★ strong match
…4975(a) and (b).
4
The Third Circuit held that
section 4975 imposes “a tax” for purposes of section 6601, which charges
interest “[i]f any amount of tax imposed by this title” is not timely paid .
See Latterman , 872 F.2d at 5 70 . In so holding the court emphasized the
statutory text, which characterizes the exa ction…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…& Dana P. Goldman,
Overpaying for Prescription Drugs: The Copay Clawback,
(2018),
https://schaeffer.usc.edu/research/overpaying-for-prescription-drugs/.)
Back to Citation
183.
Megan Thompson (2018), W
hy a Patient Paid a $285 Copay for a $40 Drug, https://www.pbs.org/newshour/health/why-a-patient-paid-a-285-copa…
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011related by meaning
use these regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Code, the notice of proposed rulemaking preceding these regulations was submitted to the Chief Counsel for Advocacy of the Small Busin…
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…
IRCCourt RulingsNov 25, 2008
…08 relates . As of the time when TRHCA was enacted , Congress had provided
specifically in sections 6601(e)(1) and 6665 ( a) that "tax" for
purposes of the Code included interest and penalties , except in
certain cases that are not relevant to our discussion .' I n
addition , Congress had provided in section 6015 ( b)(…
IRCCourt RulingsDec 8, 1987
…d Fiscal Responsibility Act of 1982, Pub. L. 97-248, ■ sec. 344(b), 96 Stat. 635, redesignated sec. 6601(e)(3) as sec. 6601(e)(2).
Title I of ERISA (the labor title) sets forth guidelines and standards governing the establishment and operation of pension plans and also establishes general standards of conduct for plan …
IRCCourt RulingsJun 18, 1999
n 6601. See Bax v.
Commissioner
, 13 F.3d 54, 56-57 (2d Cir. 1993), affg. an Order of
this Court; LTV Corp. v. Commissioner
, 64 T.C. 589, 597 (1975); see also Asciutto v. Commissioner
, T.C. Memo. 1992-564, affd. 26
F.3d 108 (9th Cir. 1994). Indeed, section 6601(e)(1) provides
that interest prescribed by section 6601 …
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…
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…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
er 1 as determined under subsection (e)
by substituting —
(i) in paragraph (1)(A), “200 percent”
for “150 percent” . . . .
2. Section 6662: Discussion Section 6662(a) is a generally applicable provision through which
all accuracy-related penalties are imposed on underpayments of tax.
Section 6662(b) lists the penalizab…
I.R.C. § 6701(c) — Penalties for aiding and abetting understatement of tax liability IRCCode / StatuteJan 4, 1995related by meaning
(c) (c) Activities of subordinates
(c)(1) (1) In general For purposes of subsection (a), the term "procures" includes—
(c)(1)(A) (A) ordering (or otherwise causing) a subordinate to do an act, and
(c)(1)(B) (B) knowing of, and not attempting to prevent, participation by a subordinate in an act.
(c)(2) (2) Subordinate F…
IRCCourt RulingsNov 21, 2007
…, we will not
consider it .
Finally, petitioners argue that interest on underpayments
under section 6601(a) should be computed from the date when the
tax return was due, taking into consideration extensions of time
to file, rather than from the original due date of the return .
Petitioners ask the Court to rule that in…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
REG-148326-05 — Proposed regulations address the calculation of amounts includible in income under section 409A(a) of the Code and the additional taxes imposed by such section… IRCProposed Rules (FR)Proposed Dec 22, 2008
…t under section 6621 plus one percentage point to determine the underpayment interest under section 6601 that would be due for such underpayment as of the last day of the taxable year for which the amount deferred is includible in income under section 409A(a). The amount of additional income tax under paragraph (d)(2) …
78 FR 13781 — Filings Required of Multiple Employer Welfare Arrangements and Certain Other Related Entities ERISAFinal Rules (FR)Mar 1, 2013
… have established a multipronged approach to MEWA abuses. The principal provisions include sections 6601, 6605, and 6606 of the Affordable Care Act. Section 6601 prohibits false statements and representations in connection with the marketing or sale of a MEWA. Section 6605 enables the Secretary to issue administrative …