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21. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024related by meaning
    is obtained on or before the date the IRS issues a notice of deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 …
22. 119 T.C. No. 6 — Robert Ancira v. Commissioner
    IRCCourt RulingsSep 24, 2002related by meaning
    titioner is not liable for the sec. 6662 penalty. 3 S.K. apparently stands for Smoothie King, which we gather was the trade name of a product. OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 The Court agrees with and…
23. I.R.C. § 6652(h) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (h) (h) Failure to give notice to recipients of certain pension, etc., distributions In the case of each failure to provide notice as required by section 3405(e)(10)(B), at the time prescribed therefor, unless it is shown that such failure is due to reasonable cause and not to willful neglect, there shall be paid, on n…
24. 75 FR 8796 — Civil Penalties Under ERISA Section 502(c)(8)
    ERISAFinal Rules (FR)Feb 26, 2010related by meaning
    ch sets forth additional circumstances in which the Service will automatically approve a request to revoke a section 204 election. Back to Citation 4.  An excise tax under Code section 4971(g)(4) generally applies, in addition to any penalty under ERISA section 502(c)(8), in the case of a failure to adopt a rehabilitat…
25. 75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Jun 16, 2010related by meaning
    URE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * *. Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows: § 301.6404-0 Table of Contents. * * * * * § 301.6404-4 Suspension of interest and c…
26. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    T.C. Memo. 2010-226 - ' UNITED STATES TAX COURT HARRY EUGENE MATHEWS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3074-09. - Filed October 19, 2010. After P failed to file his 2004 tax return, R determined a deficiency in income tax and additions to tax under sec. 6651(a) (1) and (2), I.R.C. P…
27. 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…
28. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    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…
29. 84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
    persede the guidance in Notice 87-7 for payors of designated distributions with respect to their duty to withhold under sections 3405(a)(1) or (b)(1). A. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the proposed regulation treats an APO, FPO, or DPO address as an addr…
30. 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…
31. 138 T.C. No. 7 — Research Corporation v. Commissioner
    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…
32. Notice 2009-8 — This notice provides interim guidance on recently enacted section 457A of the Code which became effective January 1, 2009. Section 457A generally provides that…
    IRCNoticesJan 26, 2009
    …e of the partnership has the same meaning as for purposes of § 702(c) (see also §§ 1.702-1(c) and 1.704-1(b)(1)(vii)). A partnership is a U.S. relevant partnership if it either (i) is required to file a return of partnership income under § 6031 or (ii) determines the distributive share of income of any partner in accor…
33. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …n Hours: 541 (270 for Treasury and 270 for DOL). Estimated Total Annual Burden Cost: $893,408 ($446,704 for Treasury and $446,704 for DOL). 2. Paperwork Reduction Act—Department of HHS
34. Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2006
    … basis the estimated cost of certain common improvements in a real estate development). .05 Section 704(c).—Contributed Property.—Requests from Qualified Master Feeder Structures, as described in section 4.02 of Rev. Proc. 2001-36, 2001-1 C.B. 1326, for permission to aggregate built-in gains and losses from contributed…
35. T.C. Summary Opinion 2006-8 — Terry Fred Burnham v. Commissioner
    IRCCourt RulingsJan 26, 2006related by meaning
    ate are treated as payments not received as an annuity and are taxable. Sec. 72(e)(2)(A). There is simply not sufficient information in this record to reach a conclusion whether some portion of the $8,000 payment is not includable in income. The Court and respondent encouraged - 10 - petitioner to provide sufficient in…
36. Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2005
    … basis the estimated cost of certain common improvements in a real estate development). .05 Section 704(c).—Contributed Property.—Requests from Qualified Master Feeder Structures, as described in section 4.02 of Rev. Proc. 2001-36, 2001-1 C.B. 1326, for permission to aggregate built-in gains and losses from contributed…
37. Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022
    IRCNoticesModified Jan 8, 2024
    …dual retirement annuity described in section 408(b). 6 The definition of “State” for purposes of 42 USC 1395x(r)(1) is in 42 USC 410(h), which provides that the term “State” includes the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa.
38. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …& Dana P. Goldman, Overpaying for Prescription Drugs: The Copay Clawback, (2018), https://schaeffer.usc.edu/​research/​overpaying-for-prescription-drugs/​.) Back to Citation 183.  Megan Thompson (2018), W hy a Patient Paid a $285 Copay for a $40 Drug, https://www.pbs.org/​newshour/​health/​why-a-patient-paid-a-285-copa…
39. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ess doctrine, courts may invalidate laws if "'men of common intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor - - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945 F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra addresses tran…
40. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011related by meaning
    use these regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Code, the notice of proposed rulemaking preceding these regulations was submitted to the Chief Counsel for Advocacy of the Small Busin…