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80 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 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…
  3. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
  4. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ess doctrine, courts may invalidate laws if "'men of common intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor - - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945 F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra addresses tran…
  5. 88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations
    IRCProposed Rules (FR)Proposed Nov 20, 2023related by meaning
    ent of Documents, U.S. Government Publishing Office, Washington, DC 20402, or by visiting the IRS website at https://www.irs.gov. Drafting Information The principal authors of these proposed are Elizabeth Boone and Hannah Kim, Office of the Associate Chief Counsel (Income Tax & Accounting), IRS, and Benjamin Weaver, Of…
  6. T.C. Memo. 2003-156 — Michael W. Duncan v. Commissioner
    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…
  7. Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t…
    IRCRevenue ProceduresSuperseded Jan 4, 2021
    Rev. Proc. 2021–4 TABLE OF CONTENTS SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE? 163 .01 Purpose of revenue procedure 163 .02 Organization of revenue procedure 163 .03 Other guidance affecting this revenue procedure 163 .04 Updated annually 167 .05 Possible future updates related to Appeals review 167 SECT…
  8. 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.
  9. 29 C.F.R. § 2570.7 — Scope of discovery.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
  10. 85 FR 66219 — Effect of Section 67(g) on Trusts and Estates
    IRCFinal Rules (FR)Oct 19, 2020★ strong match
    ion of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103. Drafting Information The principal author of these regulations is Margaret Burow of the Office of Associate Chief Counsel (Passthroughs and Special Industries). Other personnel from the Trea…
  11. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …& Dana P. Goldman, Overpaying for Prescription Drugs: The Copay Clawback, (2018), https://schaeffer.usc.edu/​research/​overpaying-for-prescription-drugs/​.) Back to Citation 183.  Megan Thompson (2018), W hy a Patient Paid a $285 Copay for a $40 Drug, https://www.pbs.org/​newshour/​health/​why-a-patient-paid-a-285-copa…
  12. 85 FR 27693 — Effect of Section 67(g) on Trusts and Estates
    IRCProposed Rules (FR)Proposed May 11, 2020related by meaning
    ies). Other personnel from the Treasury Department and the IRS, however, participated in their development. Statement of Availability of IRS Documents The IRS notice cited in this document is published in the Internal Revenue Bulletin and available from the Superintendent of Documents, U.S. Government Publishing Office…
  13. T.C. Summary Opinion 2009-77 — Gary W. & Regina G. Steele v. Commissioner
    IRCCourt RulingsMay 14, 2009
    163(h)(1), .however ; provides : "In the case~of a taxpayer other than a corporation, no deduction shall .be .allowed under this chapter for personal interest paid *,* * during the taxable year ." For this purpose, personal interest d-oes not-include ."any qualified residence interest" . Sec . 163(h)(2)(D) . Section 1…
  14. 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…
  15. 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…
  16. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …uting the termination forms resulting in an hour burden of 917 hours with an equivalent cost of $58,163.[40] It is assumed that the form will be two pages, so paper copies will cost $0.76 each, which results in a cost burden of approximately $485.[41] In total, providing the annual termination form is expected to impos…
  17. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    ents of section 2039(c)(3). Due to concessions and in order to reflect petitioner’s claim for an overpayment, Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
  18. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025related by meaning
    one fluent in English knows that the word ‘includes’ cannot be assumed to mean ‘includes only .’ . . .”) ; Waltne r , 107 T.C.M. (CCH) at 1201 (citing United States v. Lat ham , 754 F.2d 747, 750 (7th Cir. 1985) ) . In sum, petitioner’s arguments have been rejected by the courts in hundreds of cases, and we will not di…
  19. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
  20. 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 …