IRCCourt RulingsApr 2, 2020★ strong match
…he tax and the interest to which the tax relates. Aguirre v. Commissioner, 117
T.C. at 327. Section 6404(e)(1) provides that the IRS may abate assessed interest under
certain conditions that we discuss infra part III. Section 6404(e)(2) provides that
the IRS may abate interest under other conditions not relevant to thi…
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011★ strong match
01.6404-4.
* * * * *
§ 301.6404-4
Suspension of interest and certain penalties when the Internal Revenue Service does not timely contact the taxpayer. (a) Suspension.
(1) In general.
(2) Treatment of amended returns and other documents.
(i) Amended returns filed on or after December 21, 2005, that show an increase in t…
75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Jun 16, 2010★ strong match
…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 certain penalties when the Internal Revenue Service does not tim…
IRCCode / StatuteJan 24, 2020related by meaning
(c)(1)(D) (D) Public inspection of applications for exemption and notice of status In the case of a failure to comply with the requirements of section 6104(d) with respect to any exempt status application materials (as defined in such section) or notice materials (as defined in such section) on the date and in the mann…
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…
84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b) IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
persede the guidance in Notice 87-7 for payors of designated distributions with respect to their duty to withhold under sections 3405(a)(1) or (b)(1). A. Payees With a Military or Diplomatic Post Office Address
For purposes of section 3405(e)(13)(A), the proposed regulation treats an APO, FPO, or DPO address as an addr…
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 RulingsSep 13, 2010
t inv
Commissioner
Section 6404
aspect of th
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tributable to any error or delay by an officer or
he IRS in performing a ministerial or managerial .any payment of any tax described in section 6212(a )
that any error or delay in such . payment i s
to such officer or employee being erroneous o r
performing a minister…
IRCCourt RulingsSep 7, 2017
…m the day the payment was due until the tax is paid. Sec. 6601(a). In 1986
Congress enacted section 6404(e), a provision that granted the IRS the discretion
to abate interest. See Tax Reform Act of 1986, Pub. L. No. 99-514, sec. 1563(a),
100 Stat. at 2762. Under that provision, the Tax Court lacked jurisdiction to
revi…
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…
89 FR 84079 — Withholding on Certain Distributions Under Section 3405(a) and (b) IRCFinal Rules (FR)Oct 21, 2024related by meaning
t to withholding under subchapter A of chapter 3 (sections 1441 through 1446 of the Code).
1. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the regulation treats an Army Post Office (APO), a Fleet Post Office (FPO), or a Diplomatic Post Office (DPO) [2]
address as an a…
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…
76 FR 60373 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Sep 29, 2011
…ng on page 52259 through 52263 in the issue of August 22, 2011, make the following corrections:
301.6404-4
[Corrected]
1. On page 52262 in the second column, in § 301.6404-4(a)(7)(i) third paragraph, 15 lines from the bottom, the words “or Form 886-A” were inadvertently printed in italics. The words should not have bee…
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 RulingsApr 2, 2024related by meaning
) under section 219(f)(3),
404(a)(6), 404(h)(1)(B), or 404(m)(2),
(B) making distributions under section
408(d)(4),
(C) recharacterizing contributions under section 408A(d)(6), and
(D) making a rollover under section
402(c), 403(a)(4), 403(b)(8), or 408(d)(3).
(5) Coordination with periods specified by the
Secretary. —…
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
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3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
Notice 2026-9 — This notice provides guidance relating to amendments under section 501 of the SECURE 2.0 Act of 2022 for individual retirement arrangements and annuities (IRAs… IRCNoticesFeb 9, 2026related by meaning
igibility to represent taxpayers before the IRS in examinations of tax returns the preparer both prepared for the taxpayer and signed as the preparer. Additionally, unenrolled/unlicensed return preparers who participate in the AFSP agree to be subject to the duties and restrictions in Circular 230, including the restri…
Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022 IRCNoticesModified Jan 8, 2024
…dual retirement annuity described in section 408(b).
6 The definition of “State” for purposes of 42 USC 1395x(r)(1) is in 42 USC 410(h), which provides that the term “State” includes the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa.
IRCCode / StatuteJan 5, 2023related by meaning
(d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and
(d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer.
(d)(2)(C) (C) Reduction not to apply to tax shelters
(d)(…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…