145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015★ strong match
…nding income tax return. See sec. 6662(d)(2)(A).
In calculating this excess, items to which section 6662A applies are disregarded.23
See sec. 6662(d)(2). The portion of the understated tax that is attributable to an
item for which the taxpayer has substantial authority, or which the taxpayer
adequately disclosed with a…
IRCCourt RulingsJun 14, 2012★ strong match
….
3. 042 Calculation of the Amount;of thé Penalty
Although we sustain the imposition of the section 6662A penalties, we
disagree with certain aspects of respondent's calculations. Generally, section
6662A applies, as relevant here, "to any item which.is attributable to" any listed
transaction. Sec. 6662A(b)(2)(A). Resp…
IRCCode / StatuteJan 5, 2023★ strong match
(i) (i) Increase in penalty in case of nondisclosed noneconomic substance transactions
(i)(1) (1) In general In the case of any portion of an underpayment which is attributable to one or more nondisclosed noneconomic substance transactions, subsection (a) shall be applied with respect to such portion by substituting "4…
IRCCourt RulingsFeb 25, 2016
…titioner 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 taxpayer has a reportable transaction
understatement for any taxable year, there shall be added to the tax an amount
equal to 20% of the amount of such understatement." The pen…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026★ strong match
e rules regarding other penalties listed in section 6662(b).
See § 6662(c), (e)(1), (f)(1), (g)(1), (j)(1), (k) (each beginning with the phrase “[f]or purposes of this section” and explaining the meaning of terms such as “negligence,”
“substantial valuation misstatement,” and so on).
11
Section 6664(c) is titled “ Reas…
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…
IRCCode / StatuteJan 24, 2020related by meaning
(c)(2)(C) (C) Split-interest trusts In the case of a trust which is required to file a return under section 6034(a), subparagraphs (A) and (B) of this paragraph shall not apply and paragraph (1) shall apply in the same manner as if such return were required under section 6033, except that— In addition to any penalty im…
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 RulingsMar 9, 2011★ strong match
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…
IRCCourt RulingsSep 15, 2005related by meaning
Court, the two cases were
consolidated for hearing on the motions to dismiss. The hearing
was held on November 29, 2004, in San Francisco, California. Discussion
Section 6033(a)(1) requires an organization exempt from
taxation under section 501(a) to file."an annual return, stating
specifically the ite s of gross incom…
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…
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 RulingsAug 27, 2018related by meaning
arguments to justify them. We therefore hold that petitioner
- 10 -
[*10] is liable for the penalty for an underpayment attributable to a substantial understatement of income tax under section 6662(a) and (b)(2) for each year.
V. Section 6673 Sanction
Respondent moved that the Court impose sanctions against petitioner…
89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction IRCProposed Rules (FR)Proposed Mar 25, 2024
…ayer is subject to an increased penalty rate equal to 30 percent of the understatement.
See section 6662A(c). Section 6662A(b)(2) provides that section 6662A applies to any item that is attributable to any listed transaction and any reportable transaction (other than a listed transaction) if a significant purpose of su…
IRCCourt RulingsJun 6, 2016related by meaning
racy-related penalty under section
6662(a) and (b)(2) for an underpayment due to a substantial understatement
of income tax for the 2011 taxable year. Section 6662(a) imposes a 20% "accuracy-related penalty" on an
underpayment of tax attributable to any of the causes listed in section 6662(b).
These causes include "[a]…
88 FR 37186 — Malta Personal Retirement Scheme Listed Transaction IRCProposed Rules (FR)Proposed Jun 7, 2023
…ayer is subject to an increased penalty rate equal to 30 percent of the understatement.
See section 6662A(c). Section 6662A(b)(2) provides that section 6662A applies to any item which is attributable to any listed transaction and any reportable transaction (other than a listed transaction) if a significant purpose of s…
IRCCourt RulingsMay 19, 2011related by meaning
ion 6662(a) and (b) (2).
Generally, section 6662(a) and (b) (1) authorizes the
Commissioner to impose a 20-percent penalty on the portion of an
- 72 - underpayment of income tax attributable to negligence or
disregard of rules or regulations. The term "negligence"
includes any failure to make.a reasonable attempt to co…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
IRCCourt RulingsJan 14, 2013related by meaning
elated
penalty for the 2002, 2003, 2004, and 2005 tax years.
- 39 -
[*39] Subsection (a) of section 6662 imposes an accuracy-related penalty of 20% of any underpayment that is attributa le to causes specified in subsection (b).
Respondent asserts that one or botli of two causes justify the imposition of the
penalty for…
IRCCourt RulingsMar 16, 2015related by meaning
on 6662 imposes a 20% accuracy-related penalty on any underpayment
attributable to any substantial understatement of income tax. Sec. 6662(a), (b)(2). An understatement is "substantial" if it exceeds the greater of $5,000 or 10% of
5Petitioner's Wells Fargo statement for the period ending September 12,
2011, shows a ch…