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78 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments
    ERISAFinal Rules (FR)Jul 1, 2016
    … issued under 8 U.S.C. 1101(a)(15)(H)(i)(c), 1182(m), and 1184; and 29 U.S.C. 49 et seq. 2. Amend § 655.620 by revising paragraph (a) to read as follows: § 655.620 Civil money penalties and other remedies. (a) The Administrator may assess a civil money penalty not to exceed $8,908 for each alien crewmember with respect…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  3. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    … (8 U.S.C. 1182 note); Pub. L. 109-423, 120 Stat. 2900; and 8 CFR 214.2(h). ( printed page 217) § § 655.620, 655.801, and 655.810 [Amended] 2. In the following table, for each paragraph indicated in the left column, remove the dollar amount indicated in the middle column from wherever it appears in the paragraph and ad…
  4. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    … 113 Stat. 1312, 1316 (8 U.S.C. 1182 note); Pub. L. 109-423, 120 Stat. 2900; and 8 CFR 214.2(h). §§ 655.620, 655.801, and 655.810 [Amended] 2. In the table below, for each paragraph indicated in the left column, remove the dollar amount indicated in the middle column from wherever it appears in the paragraph and add in…
  5. 85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020
    ERISAFinal Rules (FR)Jan 15, 2020
    …113 Stat. 1312, 1316 (8 U.S.C. 1182 note); Pub. L. 109-423, 120 Stat. 2900; and 8 CFR 214.2(h). § § 655.620, 655.801, and 655.810 [Amended] 2. In the following table, for each paragraph indicated in the left column, remove the dollar amount indicated in the middle column from wherever it appears in the paragraph and ad…
  6. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  7. 86 FR 57272 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights
    ERISAProposed Rules (FR)Proposed Oct 14, 2021
    … Summary In summary, the total annual hour burden associated with this information collection is 17,655 hours with an equivalent cost of $2,443,629. The paperwork burden estimates are summarized as follows: Type of Review: Revision of an existing collection. Agency: Employee Benefits Security Administration, Department…
  8. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  9. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  10. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  11. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991
    …will continue to be exempt from Federal preemption under ERISA. To the same effect, see H. Rept. 98-655 (Part 1, Comm, on Education and Labor), at 39 (1984); H. Rept. 98-655 (Part 2, Comm, on Ways and Means), at 18 (1984). The reasons why the Congress acted are set forth as follows (S. Rept. 98-575, at 18-19, 1984-2 C.…
  12. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    .R.C. sec. 6662(a) penalties as redetermined in this opinion. Matthew Taggart, Ryan Andrews, Michael B. Luftman, and Charles Kolstad, for petitioners. Kris H. An, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: These cases are before the Court on petitions for redetermination of income tax and ex…
  13. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    me-generating activities relating to the items of income, he has satisfied that obligation through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation should have been divided between himself and his spouse, there is no basis for making any apportionment. …
  14. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  15. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  16. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996
    …xcess distribution 177,814 On brief, respondent concedes that the excess distribution was only $177,655.59, i.e., $327,655.59 (the taxable portion of the Transfer Refund) less $150,000. that exceeded $150,000 as an excess distribution from a qualified retirement plan. 8 Respondent then determined that petitioner was li…
  17. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
  18. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989related by meaning
    e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
  19. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  20. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…