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78 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025
    …tibility Offer in Compromise On August 25, 2022, AO Al ves received a fax from MDIA comprising Form 656, Form 433– B, and other attachments . AO Alves requested a new work unit number for the OIC and forwarded the Form 656 to the IRS Collections centralized OIC unit ( centralized unit ) for evaluation. The CDP hearing …
  2. 89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction
    IRCProposed Rules (FR)Proposed Mar 25, 2024related by meaning
    ccordance with the regulations under section 6011, the taxpayer is subject to an increased penalty rate equal to 30 percent of the understatement. See section 6662A(c). Section 6662A(b)(2) provides that section 6662A applies to any item that is attributable to any listed transaction and any reportable transaction (othe…
  3. 75 FR 53172 — Prohibited Transaction Exemption Procedures; Employee Benefit Plans
    ERISAProposed Rules (FR)Proposed Aug 30, 2010related by meaning
    s assessed by the Treasury and Labor Departments in connection with prior prohibited transactions —The current version of § 2570.35(a)(14)(v) requires ( printed page 53177) an applicant to disclose whether any excise taxes due under sections 4975(a) and (b) of the Code by reason of a consummated exemption transaction h…
  4. 20 C.F.R. § 901.12(f)(1)(iii) — Eligibility for enrollment.
    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 …
  5. T.C. Memo. 2014-227 — Brian K. Brinkley v. Commissioner
    IRCCourt RulingsOct 30, 2014related by meaning
    nsation. He then used his 2011 income tax return in an attempt to "regain" his desired preferential tax treatment that he had earlier abandoned by not challenging Zave. We cannot presume that in an agreement to pay petitioner for completing two requirements Zave actually intended for the entire amount to be paid with r…
  6. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    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…
  7. 89 FR 43675 — Prohibited Transaction Exemption 2006-06 for Services Provided in Connection With the Termination of Abandoned Individual Account Plans
    ERISAFinal Rules (FR)May 17, 2024related by meaning
    section 4975(c)(2) necessitate proposing an amendment to the exemption. Back to Citation 26.   See 29 CFR 2578.1(d)(2)(v). Back to Citation 27.   See Section I(a)(3) of this exemption amendment. Back to Citation 28.   See paragraph 29 CFR 2578.1(c)(3) of the QTA Regulation or in the case of a QTA described in Section …
  8. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    ssioner argues that such returns did not adequately disclose the prohibited transactions and that therefore the 6-year statute of limitations applies. Whether a return adequately discloses an item of income or a transaction is a question of fact. See Quick Trust v. Commissioner, 54 T.C. 1336, 1346 (1970), affd. per cur…
  9. 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 …
  10. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation 52.  5 U.S.C. 601 et seq. Back to Citation 53.  5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551. Back to Citation 54.  Public Law 104-4, 109 Stat. 48 (Ma…
  11. 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 …
  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. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019
    … and sent petitioner a notice of balance due. In response petitioner submitted to respondent a Form 656-L, Offer in Compromise (Doubt as to Liability), dated March 20, 2013, for her 2010 tax liability. Petitioner challenged the correctness of the tax liability by attaching qualifying tuition payment documentation to Fo…
  14. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007
    …ucing information to March 31, 2004. On March 31, 2004, petitioners submitted to Ms. Cochran a Form 656, Offer in Compromise, a Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals, one letter setting forth medical and retirement considerations and explaining the offer amount, and…
  15. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
  16. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …section 409(p). See Economic Growth and Tax Relief Reconciliation Act of 2001, Pub. L. 107-16, sec. 656(a), 115 Stat. 131. For ESOPs created after March 14, 2001, section 409(p) was effective for plan years ending after March 14, 2001. See id. sec. 656(d), 115 Stat. 135. Section 409(p) is intended to limit the tax bene…
  17. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    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…
  18. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …applied in the following calculation: [160 small entities × (15 minutes ÷ 60 minutes)] × $65.99 ≉ 2,656. The total cost for the first year is estimated as: $20,008,658 + $2,656 = $20,011,315. This burden in the second year is estimated as: (18,169 small entities × 5 hours) ≉ 90,857 hours. A labor rate of $165.71 is use…
  19. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
    IRCProposed Rules (FR)Proposed Dec 30, 2014
    …10,207 636,190 Legal 158 8.1 130 1,276 165,784 Sub-Total 25,517 1,980,719 Medium: IT 526 67.8 84 35,656 2,994,766 Benefits 526 49.3 62 25,932 1,616,329 Legal 526 6.2 130 3,241 421,197 Sub-Total 64,830 5,032,293 ( printed page 78595) Small IT 368 44.4 84 16,344 1,372,716 Benefits 368 32.3 62 11,886 740,879 Legal 368 4.0…
  20. 76 FR 69126 — Graduated Retained Interests
    IRCFinal Rules (FR)Nov 8, 2011related by meaning
    ge, paragraph (ii) of Example 1 of § 20.2036-1(c)(1)(ii) has been moved and renumbered as Example 8 of § 20.2036-1(c)(2)(iv) in the final regulations. Also in response to a comment, the manner of computing the amount to be included in the decedent's gross estate has been clarified at the end of § 20.2036-1(c)(2)(i). Sp…