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75 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 87 FR 56912 — Initial Regulatory Flexibility Analysis for Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Sep 16, 2022
    …he additional requirement for QPAMs ineligible due to receiving a written Ineligibility Notice is ($662 + $1,482) = $2,144 (rounded). Back to Citation 30.  At an hourly rate of $165.45 for financial professional time, the cost per application is estimated as: (4 hours * $165.45 financial professional rate) = $662 (roun…
  2. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    …any 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 percent on the portion of an underpayment attributable to negligence, disregard of rules or regulations, or a substantial unders…
  3. 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…
  4. 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 …
  5. 141 T.C. No. 19 — Andrew Wayne Roberts v. Commissioner
    IRCCourt RulingsDec 30, 2013related by meaning
    …ached to the return and there is a reasonable basis for the taxpayer's treatment of the item. Sec. 6662(d)(2)(B). The Commissioner bears the initial burden of production with respect to the taxpayer's liability for the section 6662 penalty. Sec. 7491(c). At trial the Commissioner must introduce sufficient evidence "ind…
  6. 88 FR 60018 — Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements
    IRCProposed Rules (FR)Proposed Aug 30, 2023related by meaning
    d any subcontractors consistent with the labor hour requirement of section 45(b)(8)(A) and the participation requirement of section 45(b)(8)(C); and ( 6) Whether the taxpayer made no attempt to comply with the Apprenticeship Requirements. (D) Rebuttable presumption of no intentional disregard. If a taxpayer makes the p…
  7. T.C. Memo. 2015-47 — Balvin Anthony McKnight v. Commissioner
    IRCCourt RulingsMar 16, 2015related by meaning
    on 6662 imposes a 20% accuracy-related penalty on any underpayment attributable to any substantial understatement of income tax. Sec. 6662(a), (b)(2). An understatement is "substantial" if it exceeds the greater of $5,000 or 10% of 5Petitioner's Wells Fargo statement for the period ending September 12, 2011, shows a ch…
  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. I.R.C. § 6652(c)(1)(D) — Failure to file certain information returns, registration statements, etc.
    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…
  10. 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 …
  11. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  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. 1998-52 — Robert E. Dunham v. Commissioner
    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…
  14. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997
    …Loan distributed, and petitioner received, the account balance of - 7 - petitioner's IRA; i.e., $90,662.11, which consisted of petitioner's initial deposit and earnings as follows: IRA deposit: $ 82,900.00 Earnings: 7,762.11 Total distribution: 90,662.11 Distribution of the Delaware Charter IRA In a letter to Delaware …
  15. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    Court, the two cases were consolidated for hearing on the motions to dismiss. The hearing was held on November 29, 2004, in San Francisco, California. Discussion Section 6033(a)(1) requires an organization exempt from taxation under section 501(a) to file."an annual return, stating specifically the ite s of gross incom…
  16. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    urd result. We agree. ,It is a well-established canon of statutory . interpretation that "'identical words used in different parts of the same act are intended to have the same meaning."' United States Nat'l Bank of Or: v. Indep. Ins. Agents of Am:, Inc., 508 U.S. 439/460 (1993) (quoting Commissioner v. Keystone Consol…
  17. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …09 -0Telephone 587.75 -0- 1,342.33 (1,342.33) Miscellaneous -0- 8,331.42 -0- 8,331.42 Meals -0- -0- 662.73 (662.73) Depreciation 2,248.00 2,889.00 2,889.00 -0- Total 20,603.76 37,494.61 28,331.15 9,163.46 Section 62(a)(4) allows the deduction of expenses
  18. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    ish the tax shown on the taxpayer's return for the preceding year or demonstrate that the taxpayer filed no such return. See Wheeler, 127 T.C. at 212; Schlussel v. Commissioner, T.C. Memo. 2013-185. Respondent met his burden of production by including with his summary judgment motion a redacted Form 4340 showing that p…
  19. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
    IRCProposed Rules (FR)Proposed Sep 16, 2021
    ….06 244,253 2 9,491,687 856,268 10,347,956 45 CFR 148.410(d) 0938-NEW 1,324 1,324 50 66,200 85.53 5,662,218 0 5,662,218 45 CFR 149.230 0938-NEW 326 326 24 7,819 100 783,362 0 783,362 45 CFR 149.460 0938-NEW 75 75 146.67 11,000 101 1,114,612 0 1,114,612 Total 59,914 5,609,057 359,691 19,276,093 1,189,514 20,465,607 H. S…
  20. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    …irst-year burden is estimated to be 4,857,840 hours with an equivalent total cost of approximately $662,015,640.48 ( printed page 66690) Table 6—Estimated Total First-Year Cost and Hour Burden for Issuers and FEHB Carriers to Design, Develop and Implement Needed IT System Changes and Submit Required Data Number of resp…