IRCFinal Rules (FR)Oct 8, 2019
…wko, Associate Director, (202) 530-6260; Virginia Gibbs, Manager, Policy Development Section, (202) 452-2521; Carmen Holly, Lead Financial Institution Policy Analyst, (202) 973-6122, Division of Supervision and Regulation; Laurie Schaffer, Associate General Counsel, (202) 452-2272; Matthew Suntag, Counsel, (202) 452-36…
84 FR 13814 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm… IRCProposed Rules (FR)Proposed Apr 8, 2019
… 7th Street SW, Washington, DC 20219.
Board:
Constance M. Horsley, Deputy Associate Director, (202) 452-5239; Juan Climent, Manager, (202) 872-7526; Mark Handzlik, Senior Supervisory Financial Analyst (202) 475-6636 or Sean Healey, Supervisory Financial Analyst, (202) 912-4611, Division of Supervision and Regulation; o…
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…
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…
IRCCourt RulingsFeb 6, 2024related by meaning
e funds ) .
14
[* 14] Moreover, we disagree with petitioner that Larotonda was
abrogated by the repeal of section 72(m)(4). Former section 72(m)(4)(A) was replaced by section 72(p) (1)(B), which is substantially similar to
section 72(m)(4)(A).
7
In addition, this Court has continued to cite
Larotonda as binding precede…
IRCProposed Rules (FR)Proposed Dec 7, 2018
…-6122, Division of Supervision and Regulation; or Laurie Schaffer, Associate General Counsel, (202) 452-2272, Gillian Burgess, Senior Counsel, (202) 736-5564, Matthew Suntag, Counsel, (202) 452-3694, or Kirin Walsh, Attorney, (202) 452-3058, Legal Division, Board of Governors of the Federal Reserve System, 20th and C S…
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…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
… 20219.
Board: Juan Climent, Assistant Director, (202) 872-7526, Kathryn Ballintine, Manager, (202) 452-2555, J. Kevin Littler, Lead Financial Institution Policy Analyst, (202) 475-6677, Michael Ofori-Kuragu, Senior Financial Institution Policy Analyst II, (202) 475-6623 or Christopher Powell, Senior Financial Institut…
Joint BoardRegulationsOct 18, 2016related by meaning
(f)(1)(iii) (iii) Willfully failing to make a Federal tax return in violation of the revenue laws of the United States, or evading, attempting to evade, or participating in any way in evading or attempting to evade any federal tax or payment thereof, knowingly counseling or suggesting to a client or prospective client …
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…
75 FR 51623 — Registration of Mortgage Loan Originators IRCFinal Rules (FR)Aug 23, 2010
… Currency, 250 E Street SW., Washington, DC 20219.
Board:
Anne Zorc, Counsel, Legal Division, (202) 452-3876, Virginia Gibbs, Senior Supervisory Analyst, (202) 452-2521, and Stanley Rediger, Supervisory Financial Analyst, (202) 452-2629, Division of Banking Supervision and Regulation, Board of Governors of the Federal …
IRCCourt RulingsJan 2, 2020related by meaning
principles and to deter the waste of judicial resources. See Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwiler v. Commissioner, T.C. Memo. 2016-18, at *10. The Court has provided ample warnings to petitioners of
the potential implications of continuing to assert frivolous and groundless
arguments. For…
75 FR 44656 — Registration of Mortgage Loan Originators IRCFinal Rules (FR)Jul 28, 2010
… Currency, 250 E Street SW., Washington, DC 20219.
Board:
Anne Zorc, Counsel, Legal Division, (202) 452-3876, Virginia Gibbs, Senior Supervisory Analyst, (202) 452-2521, and Stanley Rediger, Supervisory Financial Analyst, (202) 452-2629, Division of Banking Supervision and Regulation, Board of Governors of the Federal …
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
…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCFinal Rules (FR)Apr 9, 2018
…d, TTY users may contact (202) 649-5597.
Board:
Constance Horsley, Deputy Associate Director, (202) 452-5239, or Carmen Holly, Senior Supervisory Financial Analyst, (202) 973-6122, Division of Supervision and Regulation; or Gillian Burgess, Senior Counsel, (202) 736-5564, Matthew Suntag, Counsel, (202) 452-3694, or Kir…
86 FR 708 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm… IRCFinal Rules (FR)Jan 6, 2021
… 7th Street SW, Washington, DC 20219.
Board:
Constance M. Horsley, Deputy Associate Director, (202) 452-5239; Juan Climent, Assistant Director, (202) 872-7526; Mark Handzlik, Manager, (202) 475-6636; Sean Healey, Lead Financial Institution Policy Analyst, (202) 912-4611; Division of Supervision and Regulation; or Benja…
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…