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Go to I.R.C. § 6653 (not yet in the library — opens the official source)
62 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    …ilo G. and Sarah E. Chapman--docket No. 20342-94 Addition to Tax and Penalties Year Deficiency Sec. 6653(a)(1) Sec. 6662(a) 1988 $25,424 $1,237 --- 1989 12,429 --- $2,357 1990 1,574 --- 315 David E. and Gladys A. Christie--docket No. 20363-94 Addition to Tax and Penalties Year Deficiency Sec. 6653(a)(1) Sec. 6662(a) 19…
  2. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998
    …iency. Additionally, respondent concedes petitioner is not subject to an addition to tax under sec. 6653(a)(1) for the taxable year ended Dec. 31, 1988. First-Tier Second-Tier Additions to Tax Tax Year Deficiency Deficiency Sec. Sec. Sec. Ended Sec. 4975(a) Sec. 4975(b) 6653(a)(1)(A) 6653(a)(1) 6651(a)(1) 12/31/86 $11,…
  3. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    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…
  4. 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…
  5. T.C. Memo. 2014-229 — Grace Foundation, R. S. Ohendalski, Trustee v. Commissioner
    IRCCourt RulingsNov 6, 2014related by meaning
    ski's March 19, 2012, letter correctly refers to section 6652 (and not section 6552) and clearly indicates his understanding that section 6652 was the statutory provision at issue. See, e.g., Buckardt v. Commissioner, T.C. Memo. 2012-170, aff'd, ___Fed. Appx. ___, 114 A.F.T.R.2d (RIA) 2014-5745 (9th Cir. Aug. 20, 2014)…
  6. Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex…
    IRCNoticesNov 13, 2007related by meaning
    g whether an estate making the section 6166 election will be required to provide security. TAX CONVENTIONS Announcement 2007-107 Announcement 2007-107 The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first noti…
  7. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
    IRCCourt RulingsJul 25, 1974
    …nt determined deficiencies in petitioners’ Federal income taxes and additions thereto under section 6653 (a), I.R.C. 1954, as follows: Certain issues haying either been conceded or not raised in the petition, the remaining issues presented for determination -are: (1) Whether $50,000 placed in trust in 1965 and payable …
  8. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    as either unable to pay the tax or would suffer an undue hardship if he or she paid on the due date. See sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Respondent concedes that he has not met his burden of production on this issue because he failed to introduce into evidence the substitute for return that he purportedly…
  9. 70 T.C. 158 — Ma-Tran Corp. v. Commissioner
    IRCCourt RulingsMay 4, 1978
    … Issue 8. Additions to Tax Respondent determined that Ma-Tran owes an addition to tax under section 6653(a) for its fiscal years 1972 and 1973. Section 6653(a) provides that an addition to tax in the amount of 5 percent of the underpayment will accrue “If any part of any underpayment * * * is due to negligence of inten…
  10. 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…
  11. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992
    …eral income taxes and additions to tax as follows: _Additions to tax_ Sec. Sec. Sec. TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1/31/86 $64,117 $3,206.85 50 percent $16,029.25 of the interest due on underpayment of $1,097 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect…
  12. T.C. Memo. 2025-7 — Sonji Marie Mosley v. Commissioner
    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 …
  13. 89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern
    IRCFinal Rules (FR)May 6, 2024related by meaning
    The electing taxpayer must recapture such amounts on the Federal income tax return described in paragraph (h) of this section. (2) Excessive payments —(i) In general. This paragraph provides rules under section 25E(f) by reference to section 30D(g)(7)(B), which provides that rules similar to the rules of section 6417(…
  14. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    Federal income tax return on or before the payment due date unless such failure is due to reasonable cause and not due to willful neglect. The section 6651(a)(2) addition to tax applies only when an amount of tax is shown on a return filed by the taxpayer or prepared by the Secretary. Sec. 6651(a)(2), (g)(2); Cabirac v…
  15. T.C. Memo. 2014-143 — Keith Robertson v. Commissioner
    IRCCourt RulingsJul 21, 2014related by meaning
    account transcript showing that he did not file a 2009 return. The only evidence that petitioner produced was his own uncorroborated testimony, - 8 - [*8] which, for the reasons previously stated, we do not find credible. We will therefore sustain the imposition of the section 6651(a)(1) addition to tax. B. Section 66…
  16. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ed work in her capacity as Yolo's employee or officer. Consistent with our conclusion above, we sustain respondent's disallowance of these deductiòns. IV. Additions to Tax and Penalties A. s Burden of Proof Respondent bears the burden of production with regard to the section 6651(a)(1) and (2) additions to tax and the …
  17. 80 T.C. 789; 80 T.C. No. 40 — Benson v. Commissioner
    IRCCourt RulingsApr 26, 1983
    … taxes for the years 1974, 1975, and 1976, respectively, and an addition to tax pursuant to section 6653(a) of $214.01 for 1974. Respondent having conceded the section 6653(a) addition to tax, the following issues remain for our decision: (la) Whether a transaction between petitioner and a trust established by her was …
  18. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    er. Mrs. Gebman did not provide any evidence that persuades us that she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file amendment to petition filed August 28, 2019. VI. Section 6662(a) Penalties Section 6662(a) an…
  19. 100 T.C. 521; 100 T.C. No. 34 — Karem v. Commissioner
    IRCCourt RulingsJun 14, 1993
    …ral income tax for the taxable year 1987 in the amount of $3,855 and additions to tax under section 6653(a)(1)(A) and (B) in the amounts of $192.75 and 50 percent of the interest due on $3,855, respectively. The issues for decision are (1) whether petitioner Robert L. Karem (petitioner) properly excluded from the tax i…
  20. T.C. Memo. 2000-266 — Lester L. & Susan P. Samford v. Commissioner
    IRCCourt RulingsAug 24, 2000
    …determined a deficiency in petitioners' 1982 Federal income tax and additions to tax under sections 6653(a)(1) and 6659 1 in the respective amounts of $27,552, $1,377.60, and $8,265.60. Respondent also determined that petitioners are liable for an addition to tax