IRCCourt RulingsAug 27, 2026
….
B. Civil Fraud Penalties The Notices of Deficiency determined a fraud penalty pursuant to
section 6663 against Mr. Janangelo for each of the years at issue . It is
no longer an issue for resolution with respect to Mrs. Janangelo. See also
§ 6663(c).
1. Section 6663 Generally
Section 6663(a) imposes a penalty of 75% o…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024★ strong match
…s, however, that under
either test, respondent’s burden is satisfied.
27
2. Fraud Penalties
Section 6663(a) imposes a penalty equal to 75% of the taxpayer’s
underpayment of federal income tax that is due to fraud. Fraud is an
intentional wrongdoing on the part of the taxpayer with the specific
purpose of evading a tax …
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…
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 RulingsMay 28, 2003★ strong match
…etermined deficiencies in,
additions under section 6651(a)(1) to, and fraud penalties under
section 6663(a) on petitioner’s tax, as follows:
Year
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…
I.R.C. § 6652(c) — Failure to file certain information returns, registration statements, etc. IRCCode / StatuteJan 24, 2020related by meaning
(c) (c) Returns by exempt organizations and by certain trusts
(c)(1) (1) Annual returns under section 6033(a)(1) or 6012(a)(6)
(c)(1)(A) (A) Penalty on organization In the case of— there shall be paid by the exempt organization $20 for each day during which such failure continues. The maximum penalty under this subpara…
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 RulingsJan 2, 2025
…section 6651(a)(1)
1
addition to tax of $481,316 for failure to file a return timely, and a
section 6663 fraud penalty against only Mr. Hutcheson of $1,443,674.
Alternatively, he determined a section 6662(a) accuracy-related pe n alty
against both petitioners.
2
In his A nswer respondent decreased the
deficiency to $1,…
Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions IRCNoticesAug 24, 2026
…rtain information addressed in this notice will be subject to the Paperwork Reduction Act (PRA), 44 USC 3507. No collection of information will be required until approved by the Office of Management and Budget (OMB) under the PRA.
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 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 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 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…
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.
IRCCourt RulingsMar 9, 2011related by meaning
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 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 RulingsOct 19, 2010related by meaning
ions, this Court concludes that a
section 6673 penalty of $500 is appropriate. It is
"inappropriate that taxpayers who promptly pay their taxes should have the cost of Government and tax collection improperly
increased by citizens apparently unwilling to obey the law or
shoulder their assigned share of the Government c…
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…
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]…