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…
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…
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…
IRCPrivate Letter RulingsAug 13, 1999
…n into account in computing the
taxable income or credits against the tax of an individual.
Section 677(a) provides that the grantor is treated as the owner of any portion of
a trust whose income without the approval or consent of any adverse party is, or, in the
discretion of the grantor or a nonadverse party, or both…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
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…
IRCPrivate Letter RulingsAug 20, 2004
…ccount under chapter 1 in computing taxable income or credits against tax of an
individual.
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose inco me without the approval or consent of any
adverse party is, or, in the discretion of the grantor or a non…
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…
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…
IRCCourt RulingsJan 17, 2024related by meaning
ies.
Subchapter C, consisting solely of section 6751, sets forth “Procedural
Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides
evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…
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
…
IRCPrivate Letter RulingsMar 16, 2012
ection 677(a)(2) provides that the grantor shall be treated as the owner
of any portion of a trust whose income without the approval or consent of any adverse party is, or in the discretion of the grantor or an adverse party or both
may be held or accumulated for future distribution to the grantor.
Section 1.677(a) - 1…
PLR 200704006 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJan 26, 2007
…der
chapter 1 in computing the taxable income or credits against the tax of an individual).
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose inco me without the approval or consent of any
adverse party is, or in the discretion of t he grantor or an ad…
IRCPrivate Letter RulingsJul 13, 2001
…ccount under chapter 1 in computing taxable income or credits against tax of an
individual.
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose income without the approval or consent of any
adverse party is, or, in the discretion of the grantor or a nona…
IRCCourt RulingsFeb 9, 1998related by meaning
this case of most of the
enumerated badges of fraud. Accordingly, petitioner is liable
for section 6651(f) additions to tax for 1990, 1991, and 1992. Section 6654(a) imposes an addition to tax for failure to
make timely estimated income tax payments. Where prepayments of
tax do not equal the percentage of total liabil…
PLR 200418010 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsApr 30, 2004
…der
chapter 1 in computing the taxable income or credits against the tax of an individual).
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose inco me without the approval or consent of any
adverse party is, or in the discretion of the grantor or a nona…
PLR 200703011 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJan 19, 2007
…der
chapter 1 in computing the taxable income or credits against the tax of an individual).
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose inco me without the approval or consent of any
adverse party is, or in the discretion of t he grantor or an ad…
IRCPrivate Letter RulingsJul 30, 1999
… that the term "grantor" as used in the regulations under subpart E includes a corporation.
Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner
of any portion of a trust whose income without the approval or consent of any adverse
party is, or, in the discretion of the grantor or a nona…
89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAFinal Rules (FR)Jan 24, 2024related by meaning
rimes is an element; or any crime identified in ERISA section 411, regardless of whether the conviction occurred in a U.S. or foreign jurisdiction; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…