IRCCourt RulingsAug 1, 2012related by meaning
… will be eliminated in the Rule 155 computation in accordance with
respondent's concession.
Section 6662 Penalty
Respondent has the burden of producing evidence that the section 6662(a)
penalty applies. See sec. 7491(c). Section 6662(a) and (b)(1) and (2) imposes a
20% accuracy-related penalty on any underpayment of Fe…
IRCCourt RulingsJun 24, 2003related by meaning
a section 6662 accuracyrelated penalty is due with respect to petitioners' tax return
for 1999.
Section 6662(a) imposes a penalty of 20 percent of the portion of the underpayment attributable to negligence or
disregard of rules or regulations. See sec. 6662(a) and (b)(1).
Negligence is defined as any failure to make a …
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
…s, however, that under
either test, respondent’s burden is satisfied.
27
2. Fraud Penalties
Section 6663(a) imposes a penalty equal to 75% of the taxpayer’s
underpayment of federal income tax that is due to fraud. Fraud is an
intentional wrongdoing on the part of the taxpayer with the specific
purpose of evading a tax …
Joint BoardRegulationsDec 30, 2016related by meaning
(a)(9) (9) Directly or indirectly attempting to influence, or offering or agreeing to attempt to influence, the official action of any officer or employee of the Internal Revenue Service by the use of threats, false accusations, duress or coercion, by the offer of any special inducement or promise of an advantage, or b…
IRCCourt RulingsOct 19, 2010related by meaning
ions, this Court concludes that a
section 6673 penalty of $500 is appropriate. It is
"inappropriate that taxpayers who promptly pay their taxes should have the cost of Government and tax collection improperly
increased by citizens apparently unwilling to obey the law or
shoulder their assigned share of the Government c…
U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner IRCCourt RulingsDec 13, 2018related by meaning
ners are liable under section 6662(a) and
(b)(2) for an accuracy-related penalty on an underpayment due to a substantial
understatement of income tax. Section 6662(a) imposes a 20% accuracy-related penalty on any portion of
an underpayment of tax required to be shown on a return if, as provided by section
6662(b)(2), t…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
IRCCourt RulingsFeb 12, 2014related by meaning
…s petitioners' income was not from discharge of
indebtedness.
III. Accuracy-Related Penalty
Section 6662(a) imposes an accuracy-related penalty equal to 20% of the
amount of any underpayment of tax that is attributable to a substantial
understatement of income tax. By definition, an understatement is the excess of
the …
IRCCourt RulingsAug 16, 2005related by meaning
ted
penalty pursuant to section 6662(a) with respect to the
underpayment attributable to the unreported 10-percent additional
tax under section 72(t). Section 6662(a) imposes a 20-percent penalty on the portion
of any underpayment attributable to any of various factors, one
of which is negligence or disregard of rules …
IRCCourt RulingsDec 2, 2013related by meaning
ion 6662(a) and (b)(2) imposes an accuracy-related penalty equal to
20% of the amount of any underpayment of tax that is attributable to a substantial understatement of income tax. By definition, an understatement is the excess of
the tax required to be shown on the tax return over the tax actually shown on the
return.…
ERISAProposed Rules (FR)Proposed Sep 15, 2021
…e and small plans, and would be the result of a decrease in the number of Form 5500-SF filers, from 666,100 to 650,700. Such a reduction in filers would be partially offset by an increase in DFE filings, which reflects the introduction of DCGs as filing entities.
( printed page 51298)
Table 3—Estimated Burden Change by…
IRCCourt RulingsJun 17, 1997related by meaning
ederal income tax. See sec.
6662(b)(2). As relevant herein, section 6662(a) imposes an
accuracy-related penalty equal to 20 percent of an underpayment that is due to a substantial understatement of income tax. In
the case of a corporation, a substantial understatement exists if
its income tax was understated by the gre…
IRCCourt RulingsJun 9, 2009related by meaning
oner is liable for the
accuracy-related penalty under section 6662 on the ground tha
t
'there was a substantial understatement of income tax in 2004 . Section 6662(a) and (!b)(2) authorizes the Commissioner to impose
a 20-percent penalty
.if there is a substantial understatement of
income tax . A substantial understate…
89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction IRCProposed Rules (FR)Proposed Mar 25, 2024related by meaning
…ayer 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 (other than a listed transaction) if a significant purpose of su…
I.R.C. § 6652(c) — Failure to file certain information returns, registration statements, etc. IRCCode / StatuteJan 24, 2020related by meaning
(c) (c) Returns by exempt organizations and by certain trusts
(c)(1) (1) Annual returns under section 6033(a)(1) or 6012(a)(6)
(c)(1)(A) (A) Penalty on organization In the case of— there shall be paid by the exempt organization $20 for each day during which such failure continues. The maximum penalty under this subpara…
IRCCourt RulingsJun 14, 2012related by meaning
… e.g., McGehee Family Clinic v. Commissioner, T.C.:Memo. 2010-202. The penalty
structure of section 6662A does not do so
Petitioners also contend that their due process rights have been violated
because the language "substantially similár" set forth in Notice 2004 8, supra, is
void for vagueness. Petitioners believe th…
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 …
IRCCourt RulingsJan 6, 1997related by meaning
etitioners are liable for an
accuracy-related penalty of $4,870 pursuant to section 6662(a)
for 1991. Section 6662 imposes a 20-percent penalty on any portion of any underpayment that is attributable to any
substantial understatement of income tax. Sec. 6662(a)(2),
- 14 -
(b)(2). Respondent based the determination of t…
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 …