IRCCourt RulingsJan 12, 1998related by meaning
Memo. 1993-61; Ianniello
v. Commissioner
, 98 T.C. 165, 180 (1992); cf. Helvering v.
Mitchell
, 303 U.S. 391, 397 (1938) (holding that the addition to tax for fraud is remedial). Courts have considered the cases
- 8 -
cited by petitioner in the Federal income tax arena and found
that these cases did not apply for purpo…
IRCCourt RulingsAug 27, 2018related by meaning
0 and $5,379, respectively; and
(4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014
of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a)
penalties in writing by making an entry in the Correspondence Examination
Automation Case Support…
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 RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…
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 …
IRCRegulationsDec 30, 2016related by meaning
(c) (c) Method of election. A person shall make the election referred to in this section by filing the form issued for such purpose by the Internal Revenue Service, including therein the information required by such form and the instructions issued with respect thereto, and by paying the tax which the taxpayer indicate…
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 …
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
or lack of jurisdiction.
Appropriate orders will be issued.
Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
IRCCourt RulingsNov 30, 1981related by meaning
an additional 5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate. Both sides have dealt with the status of the 32-page document as a tax return but only for purposes of the sec. 6651(a) issue presented to us. Under the circumstances, w…
IRCCourt RulingsMar 22, 2007related by meaning
ddition to tax must be
sustained.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or
groundless or the taxpayer has instituted or pursued the
proceeding primarily for delay. Respondent has n…
IRCPrivate Letter RulingsDec 1, 2006related by meaning
Restructuring and Reform Act of 1998 enacted section
7422(j), thereby creating an exception to the “full payment rule.” Pub. L. No. 105-2 06, § 3104. Section 7422(j) provides that the district courts of the United States and the United States Court
of Federal Claims have jurisdiction to determine the correct amount of…
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 RulingsJul 31, 2000
…ng amounts for the
respective years from 1991 through 1993: Dr. and Ms.
Hirshkowitz-–$254,051, $136,678, and $211,120; Dr. and Ms. Desai-
–$122,750, $42,056, and $55,000; Dr. and Ms. McManus-–$20,000,
$17,921, and $18,186; and the Estate of Steven Sobo, Deceased,
- 60 -
20
In summary, respondent determined that the dis…
IRCCourt RulingsJan 2, 2025related by meaning
cluding false returns), (10) failing to file returns, and (11) dealing in
12
The revenue agent (RA) determined to assert the fraud penalty against Mr. Hutcheson. Before respondent issued the Notice of Deficiency, the RA’s immediate
supervisor approved the RA’s determination in writing as required by section 6751(b).
Se…
IRCCourt RulingsDec 30, 2013related by meaning
.
- 26 -
return or in a statement attached 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 mu…
IRCCourt RulingsAug 22, 1994
…36,964
Total disbursements 29,309,726 34,968,999 36,063,764
Net increase (decrease) of assets 5,552,678 1,895,497 6,886,506
Assets at end of period 5,552,678 7,448,175 14,334,681
Reserves for Incurred But Unpaid Claims
IRCCourt RulingsOct 19, 2010related by meaning
re to pay his 2004 taxes; and
(4) whether the Court should impose a penalty under section
6673 for petitioner's advancement of frivolous or groundless arguments in proceedings instituted primarily for protest or
delay.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the par…
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.
82 FR 60308 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 20, 2017
…ly
benefit at
URA is
greater than—
From—
To—
2019
647
647
2,734
2,734
2020
662
662
2,797
2,797
2021
678
678
2,862
2,862
2022
693
693
2,927
2,927
2023
709
709
2,995
2,995
2024
725
725
3,064
3,064
2025
742
742
3,134
3,134
2026
759
759
3,206
3,206
2027
777
777
3,280
3,280
2028 or later
794
794
3,355
3,355
1
Table II-A.
2…
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…