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21. 29 C.F.R. § 2570.4 — Parties.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
22. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962. To…
23. 29 C.F.R. § 2570.133 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
24. 29 C.F.R. § 2520.104-28 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
25. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    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…
26. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
    s follows: Authority: 26 U.S.C. 7805 * * * Section 301.6011-10 also issued under 26 U.S.C. 6011. Section 301.6011-11 also issued under 26 U.S.C. 6011. Section 301.6011-12 also issued under 26 U.S.C. 6011. Section 301.6011-13 also issued under 26 U.S.C. 6011. Section 301.6011-14 also issued under 26 U.S.C. 6011. Section…
27. 29 C.F.R. § 2560.502c-2(a) — Civil penalties under section 502(c)(2).
    ERISARegulationsJan 1, 2017related by meaning
    (a) (a) In general. (a)(1) (1) Pursuant to the authority granted the Secretary under section 502(c)(2) of the Employee Retirement Income Security Act of 1974, as amended (the Act), the administrator (within the meaning of section 3(16)(A)) of an employee benefit plan (within the meaning of section 3(3) and § 2510.3-1, …
28. 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…
29. 141 T.C. No. 19 — Andrew Wayne Roberts v. Commissioner
    IRCCourt RulingsDec 30, 2013related by meaning
    ibutee who must include the withdrawals in income pursuant to VED DEC 3 0 2013 - 2 - I.R.C. sec. 408(d) and that P is liable for the I.R.C. sec. 72(t) additional tax on early distributions from qualified retirement plans. R also determined that P is liable for an accuracy-related penalty under I.R.C. sec. 6662(a) due t…
30. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
31. 29 C.F.R. § 2570.131 — Definitions.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of the definitions in § 18.2 of this title:
32. 75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Jun 16, 2010related by meaning
    URE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * *. Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows: § 301.6404-0 Table of Contents. * * * * * § 301.6404-4 Suspension of interest and c…
33. PLR 200226012 — Tax on Reversion of Qualified Plan Assets to Employer
    IRCPrivate Letter RulingsJun 28, 2002
    …lly complete and partially incomplete, depending upon all the facts in the particular case. Under § 2512(a), if a gift is made in property, the value of the property on the date of the gift is the amount of the gift. Section 2512(b) provides that where property is transferred for less than adequate and full considerati…
34. 89 FR 84079 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCFinal Rules (FR)Oct 21, 2024related by meaning
    t to withholding under subchapter A of chapter 3 (sections 1441 through 1446 of the Code). 1. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the regulation treats an Army Post Office (APO), a Fleet Post Office (FPO), or a Diplomatic Post Office (DPO) [2] address as an a…
35. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    ng in a change in beneficial interests causes the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612. (18) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions fr…
36. 75 FR 8796 — Civil Penalties Under ERISA Section 502(c)(8)
    ERISAFinal Rules (FR)Feb 26, 2010related by meaning
    ch sets forth additional circumstances in which the Service will automatically approve a request to revoke a section 204 election. Back to Citation 4.  An excise tax under Code section 4971(g)(4) generally applies, in addition to any penalty under ERISA section 502(c)(8), in the case of a failure to adopt a rehabilitat…
37. I.R.C. § 3405(e)(12) — Special rules for pensions, annuities, and certain other deferred income
    IRCCode / StatuteJan 12, 2018related by meaning
    (e)(12) (12) Failure to provide correct TIN If— no election under subsection (a)(2) or (b)(2) shall be treated as in effect and subsection (a)(4) shall not apply to such payee. (e)(12)(A) (A) a payee fails to furnish his TIN to the payor in the manner required by the Secretary, or (e)(12)(B) (B) the Secretary notifies …
38. I.R.C. § 6662(d)(2)(B)(ii)(I) — Imposition of accuracy-related penalty on underpayments
    IRCCode / StatuteJan 5, 2023related by meaning
    (d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and (d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer. (d)(2)(C) (C) Reduction not to apply to tax shelters (d)(…
39. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
40. PLR 201149005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 9, 2011
    …s pursuant to the Date 2 Annuity Contracts, as determined pursuant to the regulations under section 2512 of the Internal Revenue Code, was equal to the fair ma rket value of the Corporation 1 Stock as of Date 2. Trusts have paid the fixed annual annuity payments to Grantor as required by the Date 2 Annuity Contracts. O…