IRCCourt RulingsJun 6, 2016related by meaning
racy-related penalty under section
6662(a) and (b)(2) for an underpayment due to a substantial understatement
of income tax for the 2011 taxable year. Section 6662(a) imposes a 20% "accuracy-related penalty" on an
underpayment of tax attributable to any of the causes listed in section 6662(b).
These causes include "[a]…
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 RulingsAug 1, 2012related by meaning
ich they rely to reduce the taxable amounts of the distributions
that they received in 2007. Thus all of the distributions are included in their gross income and taxed as ordinary income. The amounts previously reported as capital
gains will be eliminated in the Rule 155 computation in accordance with
respondent's conc…
IRCCourt RulingsJan 14, 2013related by meaning
elated
penalty for the 2002, 2003, 2004, and 2005 tax years.
- 39 -
[*39] Subsection (a) of section 6662 imposes an accuracy-related penalty of 20% of any underpayment that is attributa le to causes specified in subsection (b).
Respondent asserts that one or botli of two causes justify the imposition of the
penalty for…
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
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 …
IRCCourt RulingsJun 14, 2012related by meaning
ause, petitioners must show that the assessment of the penalties is so
harsh and oppressive as to transgress the constitutional limitation: See, 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 …
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…
IRCCourt RulingsFeb 12, 2014related by meaning
includible in income under section 61(a)(12) and subject to tax. However, this
issue is moot because petitioners' debts were not discharged but rather extinguished, and thus petitioners' income was not from discharge of
indebtedness.
III. Accuracy-Related Penalty
Section 6662(a) imposes an accuracy-related penalty equa…
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 …
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…
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 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…
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
IRCCourt RulingsMar 4, 1999related by meaning
-related penalty under
section 6662 for a substantial understatement of tax for taxable
year 1995. Section 6662(a) imposes a 20-percent penalty on the portion of an underpayment of tax attributable to, among other
things, a substantial understatement of income tax, which is
defined as an understatement that exceeds the…
75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Jul 6, 2010
…penalties as other similarly situated taxpayers (for example, sections 6011, 6707A, 6662, 6662A and 6663).
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…
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…
IRCCourt RulingsJan 31, 2008related by meaning
er sec . 6662(a) .
A
- 23 -
To reflect the foregoing,
Decision will be entered for
p etitioners in l ocket No . 4467-06 .
Decision w 11 be entered for respondent as t the deficiency and
for petitioners as to the accuracyrelated penalty under sectio n
6662(a) in docket No . 7221-06 .