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80 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 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…
  2. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    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…
  3. 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…
  4. 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…
  5. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011related by meaning
    … Amendments to the Regulations Accordingly, 26 CFR part 301 is amended as follows: ( printed page 52261) PART 301—PROCEDURE 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 as follows: 1. Revi…
  6. 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
    tment in a building” under § 216(b)(1)(B). (45) Section 264.—Certain Amounts Paid in Connection with Insurance Contracts.—Whether § 264(d)(1) applies. (46) Section 264(c)(1).—Contracts Treated as Single Premium Contracts.—Whether “substantially all” the premiums of a contract of insurance are paid within a period of 4 …
  7. 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…
  8. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    the purposes of this O pinion, we conclude without further discussion that the requirement is valid under Chevron step two. E. E xhaustion of remedies Title 26 C.F.R. sec. 1.482-1(h)(2)(ii)(B) (2006) provides that a foreign legal restriction will be taken into account only if the taxpayer has exhausted all remedies pre…
  9. Joint BoardRegulationsOct 11, 2017related by meaning
    (c) (c) Authority to impose monetary penalty (c)(1) (1) In general. (c)(1)(i) (i) The Secretary of the Treasury, or delegate, after notice and an opportunity for a proceeding, may impose a monetary penalty on any practitioner who engages in conduct subject to sanction under paragraph (a) of this section. (c)(1)(ii) (ii…
  10. 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…
  11. 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 …
  12. 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 …
  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. T.C. Memo. 2000-391 — Robert C. Geib v. Commissioner
    IRCCourt RulingsDec 28, 2000related by meaning
    filed a voluntary petition for reorganization under chapter 11 of the Bankruptcy Code (the bankruptcy case). In the bankruptcy case, the Commissioner asserted a section 4971 deficiency against the company for - 4 - failure to satisfy the minimum funding standard pursuant to section 412. In 1994, petitioner was indicte…
  15. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …the No Surprises Act. U.S.C.-Brookings Schaeffer on Health Policy. https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 262.  See Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Cert…
  16. Treas. Reg. § 1.417(e)-1(d)(7)(v)(B) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    …l period) and dividing by 12 for an actuarially equivalent monthly benefit commencing at age 65 of $261.21. Thus, in order to satisfy paragraph (d)(7)(ii)(B) of this section, the remaining portion of T's accrued benefit must be at least $1,238.79 per month ($1,500.00−$261.21) payable as a straight life annuity at norma…
  17. Notice 2024-1 — This notice provides the indexing factors to be used by group health plans and health insurance issuers to calculate the qualifying payment amount (QPA) for it…
    IRCNoticesJan 8, 2024
    …djusted QPA is $4,678 ($4,437 x 1.0543149339). 9 The 2023 adjusted QPA for the $2,100 service is $2,261 ($2,100 x 1.0768582128). The 2024 adjusted QPA is $2,384 ($2,261 x 1.0543149339).
  18. 34 T.C. 851 — West Virginia Steel Corp. v. Commissioner
    IRCCourt RulingsAug 15, 1960related by meaning
    n this report. All statutory references herein are to the Internal Revenue Code of 1939, unless otherwise specified. SEC. 291. FAILURE TO PILE RETÜRN. (a) In ease of any failure to make and file return required by this chapter, -within the time prescribed by law or prescribed by the Commissioner in pursuance of law, un…
  19. T.C. Summary Opinion 2002-108 — Claudia J. Dunn v. Commissioner
    IRCCourt RulingsAug 22, 2002
    …T 11/11/1998 1/25/1999 Petitioner made four payments to the University of Phoenix in 1998 totaling $261.47. Petitioner also made two payments to the University of Phoenix in 1999 for expenses that were incurred in 1998. The latter two expenses cannot be treated as qualified higher education expenses for 1998. Petitione…
  20. PBGCPBGC Opinion LettersSep 28, 1994
    …lia ble for any i nteres t and penal ties assesse d with re spec t to such prem iums. 2 9 C .F.R. § 261 0.26 (a). Although the plan admin ist rat or has the duty of ensu ring that p remiu ms are [*4] p aid, the paym ents, alo ng with penalt ies and interest, may generally be paid fr om plan assets. n2 The conference co…