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75 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 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, 2010related by meaning
    to the transaction on or before the first date on which the transaction is required to be disclosed by the person under section 6011. Special Analyses It has been determined that this Treasury decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not …
  2. T.C. Memo. 2000-250 — Susan Jane Hoyez, C.P.A. v. Commissioner
    IRCCourt RulingsAug 10, 2000related by meaning
    6, 682 (1977); Pawlak v. Commissioner , T.C. Memo. 1995-7. Finally, there is no indication - 8 - 2 Petitioner contends that under IRS Publication 560, Retirement Plans for the Self-Employed, contributions can be retroactively applied to the previous year if the contributions are made by the due date of the employer’s r…
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …any, which in turn would trigger an inclusion in the gross income of the U.S. company under section 951(a)(1)(A) of the Internal Revenue Code of 1954 (26 U.S.C. sec. 951(a)(1)(A)). Procter & Gamble
  4. 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…
  5. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    ust decide (1) whether section 4979A(a) imposes an excise tax on petitioner for its taxable year 2005 and (2) if so, whether the period of limitations under section 4979A(e)(2)(D) has expired for assessing that tax for that year. We turn first to whether section 4979A(a) imposes an excise tax on petitioner for its taxa…
  6. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    ion 6662(a) and (b) (2). Generally, section 6662(a) and (b) (1) authorizes the Commissioner to impose a 20-percent penalty on the portion of an - 72 - underpayment of income tax attributable to negligence or disregard of rules or regulations. The term "negligence" includes any failure to make.a reasonable attempt to co…
  7. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    nd.8 SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg g, Hyd…
  8. 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…
  9. T.C. Summary Opinion 2006-170 — Nader Ghazitehrani and Farzaneh Zamanizadeh v. Commissioner
    IRCCourt RulingsOct 23, 2006related by meaning
    ng, An appropriate decisio n will be entered . UNITED STATES TAX COURT WASHINGTON , D .C . 20217-000 2 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 IIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII I 7004 1160 0000 9602 408 2 GHAZ100 NOTIFY 3E __ GHAZ I T EHRAN , . 2404 SE 1'61a j VANCOWER W , ,~ 56 150« 02 : .1/02/06 EW W A…
  10. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023related by meaning
    26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). * * * * * Section 1.861-12T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). * * * * * Section 1.861-13T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). * * * * * Section 1.861-14T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 77…
  11. 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 …
  12. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    n 6662(a) and (b)(1) and (2), a taxpayer may be liable for a penalty of20% 5 Over petitioner's objection respondent introduced a literal transcript of account for petitioner's 2010 tax year. The literal transcript contains no reference to any SFRs. Even if it did, the literal transcript does not establish that the requ…
  13. 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 …
  14. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    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…
  15. 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 …
  16. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    foregoing quoted terms are specially defined and used under the "Public Salary Tax Act of 1939" ; 3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor "taxpayer," nor "non-resident alien," nor any other "legal entity" "made liable for" or "subject to" any "internal reve…
  17. T.C. Summary Opinion 2018-59 — Kelly Chafin Lim v. Commissioner
    IRCCourt RulingsDec 26, 2018
    …ax of $1,335. The only substantive adjustment giving rise to the deficiency was an adjustment of $7,951 based on the defaulted loan and the Form 1099-R issued by T. Rowe Price. In a timely filed petition, petitioner commenced the present case challenging respondent's deficiency determination. At trial respondent conced…
  18. 36 T.C. 818 — Roff v. Commissioner
    IRCCourt RulingsAug 10, 1961related by meaning
    e Court. We have examined the pleadings and are satisfied that the statutory notice of deficiency and pleadings as a whole place this matter in issue. We hold that the petitioner realized ordinary income rather than capital gain upon the sale of the annuity contracts involved herein. Petitioner contends, alternatively,…
  19. I.R.C. § 3405(e)(12) — Special rules for pensions, annuities, and certain other deferred income
    IRCCode / StatuteJan 12, 2018related by meaning
    (e)(12) (12) Failure to provide correct TIN If— no election under subsection (a)(2) or (b)(2) shall be treated as in effect and subsection (a)(4) shall not apply to such payee. (e)(12)(A) (A) a payee fails to furnish his TIN to the payor in the manner required by the Secretary, or (e)(12)(B) (B) the Secretary notifies …
  20. T.C. Memo. 2020-101 — Tamecca Seril a.k.a. Tamecca Tillard v. Commissioner
    IRCCourt RulingsJul 8, 2020related by meaning
    de imposes a 20% penalty upon the portion of any underpayment of tax that is attributable to (among other things) "[a]ny substantial understatement of income tax." Sec. 6662(a), (b)(2). An understatement of income tax is "substantial" if it exceeds the greater of $5,000 or 10% of the tax required to be shown on the ret…