IRCCourt RulingsDec 11, 2003★ strong match
…’s imposition of a
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25-percent addition to tax under section 6651(a).
B. Respondent’s Section 6653(a)(1) Determination
Section 6653(a)(1) imposes an addition to tax equal to 5
percent of the entire underpayment if any portion of such
underpayment is due to negligence or intentional disregard of
rules or regulatio…
IRCCourt RulingsJul 15, 1997
…Jane E. Prince, docket No. 22467-93
Additions to Tax
Sec. Sec. Sec. Sec.
Year
Deficiency
6651(a)(1)
6653(a)(1)(A)
6653(a)(1)(B)
6661(a)
1987 $76,684 19,360 4,213
1
19,171
1
50 percent of the interest due on the deficiency.
Douglas R. Prince, D.D.S., M.S., P.C., docket No. 8457-94
Additions to Tax
Taxable Secs. Secs.
Ye…
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…
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…
IRCCourt RulingsAug 13, 1987
… Federal income tax for 1981 in the amount of $11,796.28, and additions to tax pursuant to sections 6653(a)(1) and 6653(a)(2) of $598.81 and 50 percent of the interest due on the underpayment attributable to negligence, respectively.
The issues for decision are: (1) Whether a payment made from petitioner Jerry Larotond…
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…
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…
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…
IRCCourt RulingsNov 30, 1981
… and that additions to tax should be imposed under sections 6651(a)(1) (failure to file return) and 6653(a) (negligence) in the amounts of $274.75 and $110.55, respectively.
The issues for decision are:
(1) Whether petitioners are liable for an income tax deficiency;
,(2) Whether petitioners are liable for an addition …
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 RulingsFeb 5, 1998
…ederal income tax and additions to tax as
follows:
Additions to Tax
Deficiency
Sec. 6651(a)(1)
Sec. 6653(a)(1)(A)
Sec. 6653(a)(1)(B)
Sec. 6661
$308,201 $61,705.20 $146,064.61 50 percent of the $77,038.75
interest due on
$308,201
- 2 -
1
Respondent concedes that: (1) $34,574 of losses disallowed
in the notice of deficie…
IRCCourt RulingsNov 12, 1981
…50.54 for 1975 and $795.58 for 1976. Also, for 1975, he determined an addition to tax under section 6653(a) of the Internal Revenue Code of 1954 of $92.53. After concessions by the petitioners, the issues for decision are: (1) Whether in 1975 the petitioners made a deductible contribution to a validly created individua…
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 RulingsFeb 25, 2016related by meaning
ed for Forms 5329. Petitioner once again does not argue that his
- 38 -
[*38] failure to timely pay was due to reasonable cause and not due to willful neglect. Accordingly, petitioner 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 t…
IRCRegulationsDec 19, 2016related by meaning
(e) (e) Manner of payment. The amount imposed under subsection (a), (b), or (c) of section 6652 and this section on any person shall be paid in the same manner as tax upon the issuance of a notice and demand therefor.
IRCCourt RulingsOct 19, 2010related by meaning
section 6651(a) (1) and (2).
"The sec. 6651(a) (1) addition to tax is reduced by the
amount of the sec. 6651(a) (2) addition to tax for any month (or fraction thereof) to which an addition to tax applies under both
sec. 6651(a) (1) and (2). See sec. 6651(c) (1).
"We acknowledge that petitioner failed to assign any err…
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 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…
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…
IRCCourt RulingsMay 20, 1976
… Federal income tax in the amount of $9,554.75 and addition to tax for the negligence penalty (sec. 6653(a), I.R.C. 1954) in the amount of $477.74. “Petitioner” shall hereinafter refer to petitioner Angelo J. Bianchi. The issues for decision are:
(1) Whether petitioner’s wholly owned subchapter S corporation, on its in…