IRCCourt RulingsDec 18, 2012
…
CB9250
FFB1604
NWB8531
Additional rent
$6,950 $6,324 $5,320
12,900 15,295 14..222
19,850 21,619 19,542
-0- (1,126) -0-
-0- (1,561) -0-
(3,763) (2,116) -0-
-0- (1.461) -016,087 15,355 19,542
Respondent determined that each petitioner realized one-half of the total rental
78 FR 20039 — Reportable Events and Certain Other Notification Requirements PBGCProposed Rules (FR)Proposed Apr 3, 2013related by meaning
llion.
(1) Form 200 must be filed with PBGC no later than 10 days after the due date for any required payment for which payment was not made when due. (2) If a contributing sponsor or the ultimate parent completes and submits Form 200 in accordance with this section, PBGC will consider the notification requirement in s…
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…
76 FR 76235 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements ERISAProposed Rules (FR)Proposed Dec 6, 2011related by meaning
judge.
For section 521 proceedings, this section shall apply in lieu of § 18.57 of this title:
(a)
Proposed findings of fact, conclusions, and order. Within twenty (20) days of the filing of the transcript of the testimony, or such additional time as the administrative law judge may allow, each party may file with the…
80 FR 57709 — Reliance Standards for Making Good Faith Determinations IRCFinal Rules (FR)Sep 25, 2015related by meaning
llection of information must be retained as long as their contents might become material in the administration of any internal revenue law.
Background This document contains amendments to 26 CFR part 53 under chapter 42, subtitle D of the Internal Revenue Code (Code). To avoid certain excise taxes under chapter 42, a p…
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 …
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
ns
were made negligently or intentionally.”) (emphasis added);
see Mathews
v.
Chevron Corp.,
362 F.3d 1172, 1183 (9th Cir. 2004).
Back to Citation
37. 84 FR 33348, note 303. The Department observes that this requirement is also consistent with, for example, the requirement under section 206 of the Advisers Act, which …
IRCPrivate Letter RulingsDec 1, 2006related by meaning
c Oil Producing Co. v. United States
, 35 F. Supp. 766 (Ct.
Cl. 1940)). Further, an ov erpayment of tax can exist only if the amount remitted with the request for an extension of time to file exceeds the final tax liability shown on Form 706. Id.
Section 7422 authorizes a taxpayer to institute a civil action for refund…
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 …
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…
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 …
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…
IRCCourt RulingsJun 10, 1996
…ommissioner
, supra
at 265
(citing United States v. American Trucking Associations, Inc.
,
supra
at 542-543).
In interpreting any statue, we attempt to determine
Congress' intent in using the statutory language being construed.
United States v. American Trucking Associations, Inc.
, supra
at
542; Helvering v. Stockholm…
ERISARegulationsJan 1, 2017related by meaning
(j) (j) Liability.
(j)(1) (1) If more than one person is responsible as administrator for the failure to file the annual report, all such persons shall be jointly and severally liable with respect to such failure.
(j)(2) (2) Any person against whom a civil penalty has been assessed under section 502(c)(2) pursuant to a…
143 T.C. No. 5 — Parimal H. Shankar & Malti S. Trivedi v. Commissioner IRCCourt RulingsAug 26, 2014
…ive participants contributing to IRAs that, in 1981, it had eliminated. See S.
Rept. No. 99-313, at 542 (1986), 1986-3 C.B. (Vol. 3) 1, 542 (accompanying H.R.
3838, 99th Cong. (1985), enacted as the Tax Reform Act of 1986, Pub. L. No. 99514, 100 Stat. 2085). The Committee on Finance explained the reinstatement of
the r…
Joint BoardRegulationsDec 30, 2016related by meaning
(b) (b) Depositions upon oral examination
(b)(1) (1) A deposition must be taken before an officer duly authorized to administer an oath for general purposes or before an officer or employee of the Internal Revenue Service who is authorized to administer an oath in Federal tax law matters.
(b)(2) (2) In ordering a depos…
Joint BoardRegulationsDec 30, 2016related by meaning
(d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved.
(d)(4)(iv) (iv) Public i…
IRCCourt RulingsMar 12, 2008
…013 6,681 77,69 4
25 77,694 25,000 52,694 5,216 57,90 9
26 57,909 25,000 32,909 3,633 36,54 2
27 36,542 25,000 11,542 1,923 13,46 6
We note four preliminary points about petitioner's
calculation . First, the annual account balance is reduced by
$25,000 (see col . 4, above) before the stated interest rate, 8
percent, is…
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…
IRCCourt RulingsMar 22, 2007
…ral income tax of $4,333, as well as
additions to tax under section 6651(a)(1) and (2) of $975 and
$542, respectively, and section 6654 of $171.
1
- 2 -
1
(...continued)
the Internal Revenue Code (Code), as amended. Amounts are
rounded to the nearest dollar.
2
Respondent has conceded the sec. 6651(a)(2) addition to tax…