IRCCourt RulingsMay 28, 2003★ strong match
…burden
of proof with respect to the underlying deficiency. Parks v.
Commissioner
, 94 T.C. 654, 660-661 (1990); Petzoldt v. Commis-
sioner
, 92 T.C. 661, 700 (1989). The Commissioner must prove
only that an underpayment exists, and not the precise amount of
such underpayment. DiLeo v. Commissioner
, 96 T.C. 858, 873
(1…
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…
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 tax under chapter 43 of subtitle D of the Internal Revenue Code (Code) shall be subject to penalties for failure to furnish a copy to the taxpayer under section 6695(a) of the Code, failure to sign the return under section 66…
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…
IRCCourt RulingsDec 30, 2013related by meaning
the amount of tax imposed that is shown on the return, reduced by any
rebate. Sec. 6662(d)(2)(A). The amount of the understatement is reduced by that portion of the understatement that is attributable to (1) the tax treatment of any
item if there is or was substantial authority for such treatment, or (2) any item if
t…
IRCCourt RulingsNov 10, 2020related by meaning
payer had "substantial authority" or, in the case of items adequately
disclosed, a "reasonable basis". Sec. 6662(d)(2)(B). Section 6664(c)(1) provides an exception to the imposition of the section 6662(a) accuracy-related penalty if it
is shown that there was reasonable cause for the underpayment and the taxpayer
acted…
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 …
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 …
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 22, 2008related by meaning
to willful neglect . See Higbee
v . Commissioner , supra at 446-447 (stating that the taxpayer
bears the burden of proof regarding reasonable cause) . Accordingly, on this issue we sustain respondent's determination .
V . Section 6673(a)(1 )
Section 6673(a)(1) authorizes this Court to penalize up to
$25,000 a taxpayer …
IRCCourt RulingsJul 31, 2000
…54. Lakewood paid this premium, and, at the end
of that year, the conversion credit balance was $39,661.57
($48,861.20 - $10,907.54 + $1,707.91); the $1,707.91 is the
interest of 4.5 percent earned on the conversion credit balance
- 56 -
(($39,661.57 - $1,707.91) x 4.5% = $1,707.91)). None of the
conversion credit bala…
IRCCourt RulingsJan 22, 2025related by meaning
no substantive merit in this
case. Accordingly, we find that petitioner is liable for the addition to tax
under section 6651(a)(1).
B. Failure to Pay Section 6651(a)(2) authorizes the imposition of an addition to tax
for failure to timely pay the amount shown as tax on a f ederal income
tax return unless the taxpayer …
IRCCourt RulingsFeb 9, 1998related by meaning
this case of most of the
enumerated badges of fraud. Accordingly, petitioner is liable
for section 6651(f) additions to tax for 1990, 1991, and 1992. Section 6654(a) imposes an addition to tax for failure to
make timely estimated income tax payments. Where prepayments of
tax do not equal the percentage of total liabil…
79 FR 71019 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 1, 2014
…16
618
618
2,610
2,610
( printed page 71020)
2017
631
631
2,667
2,667
2018
646
646
2,728
2,728
2019
661
661
2,791
2,791
2020
676
676
2,855
2,855
2021
691
691
2,921
2,921
2022
707
707
2,988
2,988
2023
724
724
3,057
3,057
2024
740
740
3,127
3,127
2025 or later
757
757
3,199
3,199
1
Table II-A.
2
Table II-B.
3
Table II…
IRCCode / StatuteJan 24, 2020related by meaning
(c)(1)(D) (D) Public inspection of applications for exemption and notice of status In the case of a failure to comply with the requirements of section 6104(d) with respect to any exempt status application materials (as defined in such section) or notice materials (as defined in such section) on the date and in the mann…
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…
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, 2024
…, or any product derived from oil or gas, is a bulk sale for purposes of § 613A(d)(2). (5) Sections 661 and 662.—Deduction for Estates and Trusts Accumulating Income or Distributing Corpus; Inclusion of Amounts in Gross Income of Beneficiaries of Estates and Trusts Accumulating Income or Distributing Corpus.—Whether th…
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…
75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable… IRCFinal Rules (FR)Jul 19, 2010
…ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
PBGCRegulationsJan 1, 2017
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…