I.R.C. § 6701(c) — Penalties for aiding and abetting understatement of tax liability IRCCode / StatuteJan 4, 1995related by meaning
(c) (c) Activities of subordinates
(c)(1) (1) In general For purposes of subsection (a), the term "procures" includes—
(c)(1)(A) (A) ordering (or otherwise causing) a subordinate to do an act, and
(c)(1)(B) (B) knowing of, and not attempting to prevent, participation by a subordinate in an act.
(c)(2) (2) Subordinate F…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCPrivate Letter RulingsDec 20, 2013
…om the sales or exchanges of capital assets shall
be allowed only to the extent allowed in sections 1211 and 1212.
Section 1.165-1(b) states that to be allowable as a loss under section 165(a), a
loss must be evidenced by a closed and completed transac tions, fixed by identifiable
events, and except as otherwise provid…
Joint BoardRegulationsDec 30, 2016related by meaning
(d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved.
(d)(4)(iv) (iv) Public i…
IRCCourt RulingsSep 10, 2015related by meaning
n October 13, 2011, petitioner's wife sent a final letter to Settlement
Officer Owyhng informing him that petitioner had received his October 6, 2011, letter, and that petitioner had requested an extension of time on September 26,
-7-
[*7] 2011. The letter also reiterated that petitioner had no access to a computer
and…
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 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
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
ERISACode / StatuteJan 6, 2025related by meaning
Notwithstanding any other provision of law, this part shall supersede any law of a State which would directly or indirectly prohibit or restrict the use of an automatic contribution arrangement, described in section 1193(d)(2) of this title, for a pension-linked emergency savings account. The Secretary may promulgate r…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026related by meaning
The Tax Court denied the IRS’s motion to dismiss the case for lack of jurisdiction. In a unanimous opinion, the Tax Court held that section 7508A(d) (as amended in 2019) unambiguously provided for an automatic and mandatory postponement period that incorporated all of the acts referenced by section 7508A(a), from the e…
IRCCourt RulingsJun 25, 1981
…s from sales or exchanges of capital assets shall be allowed only to the extent allowed in sections 1211 and 1212.
ERISA § 3002(e) (29 U.S.C. § 1202) — Procedures with respect to continued compliance with Internal Revenue requirements relating to participation, vesting, and funding standards ERISACode / StatuteJan 5, 2015related by meaning
(e) (e) Consultative requirements respecting promulgation of proposed or final regulations The Secretary of the Treasury shall consult with the Pension Benefit Guaranty Corporation with respect to any proposed or final regulation authorized by subpart C of part I of subchapter D of chapter 1 of title 26, or by sections…
Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona… IRCNoticesModified Dec 22, 2008
…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 …
ERISACode / StatuteJan 4, 1995related by meaning
(a)(6) (6) such other matter as any of the committees referred to in section 1221 of this title may refer to it.
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 …
75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Jul 6, 2010related by meaning
to the transaction on or before the first date on which the transaction is required to be disclosed by the person under section 6011.
Special Analyses It has been determined that this Treasury decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not …
IRCCourt RulingsMay 19, 1986
…. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; First National Bank of Evanston v. United States, 624 F. Supp. 763 (N.D. Ill. 1985); Bacchus v. United States, No. 82-8930 (D. N.J., July 3, 1985); E…
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 …
IRCCourt RulingsNov 25, 2008related by meaning
e Tax Court
(and the Tax Court shall have
jurisdiction) to determine the
appropriate relief available to the
individual under this section * * *
- 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4
This amendment applies "with respect to liability for taxes
arising or remaining unpaid on or after …
89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction IRCProposed Rules (FR)Proposed Mar 25, 2024related by meaning
01:PR (REG-108761-22) room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Charles D. Wien of the Office of Associate Chief Counsel (Passthroughs & Special Industries), (202) 317-5279; concerning submissions…
IRCCourt RulingsAug 6, 1991related by meaning
Petitioners’ third prong asserts that, in any event, the lump-sum payment and the annuity payments to which he was entitled came from separate accounts and that, consequently, the former payment was not received under an “annuity contract” so as to make section 72(e) applicable. Initially, we note that section 1.72-2(a…