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 …
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…
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
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…
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…
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…
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…
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…
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
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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…
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 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…
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 …
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…
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 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…
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…
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,…
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 …
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…