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74 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 24 T.C. 460 — Northwest Automatic Products Corp. v. United States
    IRCCourt RulingsJun 23, 1955related by meaning
    a determination of whether we had jurisdiction or not once it should be held that the method prescribed by statute is not the exclusive method. * * * See also, Henry Wilson, 16 B. T. A. 1280 (1929); William M. Greve, 37 B. T. A. 450 (1938); John A. Gebelein, Inc., 37 B. T. A. 605 (1938); Oscar Block, 2 T. C. 761 (1943…
  2. 88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac…
    IRCProposed Rules (FR)Proposed Jul 12, 2023
    …C.-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2020/​08/​04/​fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insurance.
  3. 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…
  4. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    e rules regarding other penalties listed in section 6662(b). See § 6662(c), (e)(1), (f)(1), (g)(1), (j)(1), (k) (each beginning with the phrase “[f]or purposes of this section” and explaining the meaning of terms such as “negligence,” “substantial valuation misstatement,” and so on). 11 Section 6664(c) is titled “ Reas…
  5. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    IRCCourt RulingsAug 27, 2018related by meaning
    arguments to justify them. We therefore hold that petitioner - 10 - [*10] is liable for the penalty for an underpayment attributable to a substantial understatement of income tax under section 6662(a) and (b)(2) for each year. V. Section 6673 Sanction Respondent moved that the Court impose sanctions against petitioner…
  6. 78 FR 53704 — Employee Retirement Benefit Plan Returns Required on Magnetic Media
    IRCProposed Rules (FR)Proposed Aug 30, 2013related by meaning
    ublic hearing is scheduled, notice of the date, time, and place of the public hearing will be published in the Federal Register . Drafting Information The principal authors of these regulations are William Gibbs and Pamela R. Kinard, Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities…
  7. Treas. Reg. § 54.6694-3(a) — Penalty for understatement due to willful, reckless, or intentional conduct.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) In general. A person who is a tax return preparer of any return or claim for refund of excise tax under chapter 43 of subtitle D of the Internal Revenue Code (Code) shall be subject to penalties under section 6694(b) of the Code in the manner stated in § 1.6694-3 of this chapter.
  8. 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 …
  9. 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 …
  10. 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…
  11. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    mates that plans will produce ( printed page 36944) 730,346 notices in 2022.[206] This results in a cost burden of approximately $18,259 in 2022.[207] DOL shares this burden equally with the Department of the Treasury. Therefore, the total cost burden for DOL is approximately $9,129 and the total cost burden for the Tr…
  12. 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 …
  13. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ds of thousands of dollars in DISC commissions each year from a well-established business, and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount. -28IV. Section 6662(a) Penalty Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
  14. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  15. 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…
  16. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    nd.8 SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg g, Hyd…
  17. T.C. Memo. 2015-164 — Edward N. Tobias & Suzanne M. Koegler v. Commissioner
    IRCCourt RulingsAug 18, 2015
    …veral years previously. Between 2003 and 2006 petitioners made additional after-tax investments of $346,154 in the Allstate annuity contract. In March 2007 petitioners surrendered the Allstate annuity and transferred the proceeds to a variable annuity from ING USA Annuity & Life Insurance Company (ING). The value of th…
  18. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997
    T.C. Memo. 1997-346 UNITED STATES TAX COURT WILLIAM L. REESE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18442-95. Filed July 29, 1997. 1. Held : P is taxable on a pension plan distribution because he failed to roll over that distribution within the 60-day period prescribed by sec. 402(a)(5)…
  19. T.C. Summary Opinion 2014-92 — Alex Halo v. Commissioner
    IRCCourt RulingsSep 11, 2014
    …me the entire amount of Social Security benefits he received during taxable year 2010, totaling $34,346.50. Background Petitioner was approximately 50 years of age at the end of 2010. During that year petitioner did not earn any wages, salaries, professional fees, or other amounts derived from, or received for, persona…
  20. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024related by meaning
    is obtained on or before the date the IRS issues a notice of deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 …