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70 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    er. Mrs. Gebman did not provide any evidence that persuades us that she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file amendment to petition filed August 28, 2019. VI. Section 6662(a) Penalties Section 6662(a) an…
  2. 74 T.C. 651 — Judd v. Commissioner
    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…
  3. 84 FR 26605 — Exception for Interests Held by Foreign Pension Funds
    IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
    timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place for the public hearing will be published in the Federal Register . Drafting Information The principal authors of these proposed regulations are Joshua Rabon, formerly with the Office of Associate Chief Counsel (Intern…
  4. 142 T.C. No. 21 — Whistleblower 11332-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    142 T.C. No. 21 UNITED STATES TAX COURT WHISTLEBLOWER 11332-13W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11332-13W. Filed June 4, 2014. Whistleblower W reported a tax fraud scheme, involving W's employer and related entities, to the Government. W provided the Government with information re…
  5. 88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCFinal Rules (FR)Feb 23, 2023related by meaning
    dent of Documents, U.S. Government Publishing Office, Washington, DC 20402, or by visiting the IRS website at http://www.irs.gov. Drafting Information The principal author of these final regulations is Casey R. Conrad of the Office of the Associate Chief Counsel (Procedure and Administration). Other personnel from the …
  6. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    as either unable to pay the tax or would suffer an undue hardship if he or she paid on the due date. See sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Respondent concedes that he has not met his burden of production on this issue because he failed to introduce into evidence the substitute for return that he purportedly…
  7. T.C. Memo. 2012-94 — Child Adult Intervention Services, Inc. v. Commissioner
    IRCCourt RulingsMar 28, 2012related by meaning
    ctive for determinations made after October 16, 2006, this Court has jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v. Commissioner, 130 T.C. 44, 48 & n.4 (2008). - 6 - Respondent does not dispute that petit…
  8. T.C. Summary Opinion 2006-170 — Nader Ghazitehrani and Farzaneh Zamanizadeh v. Commissioner
    IRCCourt RulingsOct 23, 2006related by meaning
    ng, An appropriate decisio n will be entered . UNITED STATES TAX COURT WASHINGTON , D .C . 20217-000 2 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 IIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII I 7004 1160 0000 9602 408 2 GHAZ100 NOTIFY 3E __ GHAZ I T EHRAN , . 2404 SE 1'61a j VANCOWER W , ,~ 56 150« 02 : .1/02/06 EW W A…
  9. IRCRegulationsJul 26, 2016
    …2.5 2.3 2.2 111 3.8 3.5 3.3 3.2 3.0 2.8 2.6 2.4 2.3 2.1 112 3.7 3.5 3.3 3.1 2.9 2.8 2.6 2.4 2.2 2.1 113 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.4 2.2 2.0 114 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.3 2.1 2.0 115 3.7 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.1 1.9 Table VI—Ordinary Joint Life and Last Survivor Annuities; Two Lives—Expected Return Mult…
  10. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025related by meaning
    Memo. 2002-18, 83 T.C.M. (CCH) 1107 , 1108– 10 (imposing penalty of $2,000 under section 6673(a)), af f’ d , 54 F. App ’ x 254 (9th Cir. 2002) ; s ee G reat - West Life Assurance Co. v. United States , 678 F.2d 180, 183 ( Ct. Cl. 1982) (“The determination of where income is derived or ‘sourced’ is generally of no mome…
  11. Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4…
    IRCNoticesObsolete Dec 26, 2007
    …ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
  12. 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…
  13. Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr…
    IRCAnnouncementsMay 9, 2005
    …ALTH PLANS Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
  14. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
    e taxes Pensions Reporting and recordkeeping requirements 26 CFR Part 301 Employment taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, 26 CFR parts 1, 53, 54 and 301 are proposed to be amended as follows: PART 1…
  15. 76 FR 36996 — Extension of Time for Filing Returns
    IRCFinal Rules (FR)Jun 24, 2011related by meaning
    (f) Penalties. See section 6651 for failure to file an estate or trust income tax return or failure to pay the amount shown as tax on the return. (g) Effective/applicability dates. This section applies to applications for an automatic extension of time to file an estate or trust income tax return filed on or after Jun…
  16. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006related by meaning
    c Oil Producing Co. v. United States , 35 F. Supp. 766 (Ct. Cl. 1940)). Further, an ov erpayment of tax can exist only if the amount remitted with the request for an extension of time to file exceeds the final tax liability shown on Form 706. Id. Section 7422 authorizes a taxpayer to institute a civil action for refund…
  17. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    IRCCourt RulingsAug 27, 2018related by meaning
    0 and $5,379, respectively; and (4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014 of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a) penalties in writing by making an entry in the Correspondence Examination Automation Case Support…
  18. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    ish the tax shown on the taxpayer's return for the preceding year or demonstrate that the taxpayer filed no such return. See Wheeler, 127 T.C. at 212; Schlussel v. Commissioner, T.C. Memo. 2013-185. Respondent met his burden of production by including with his summary judgment motion a redacted Form 4340 showing that p…
  19. 87 FR 52618 — Requirements Related to Surprise Billing
    IRCFinal Rules (FR)Aug 26, 2022
    …s Act.” U.S.C.-Brookings Schaeffer on Health Policy. (March 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 114.  2 U.S.C. 1501 et seq. (1995). Back to Citation 115.  See House Conf. Rep. No. 104-73…
  20. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    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…