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  1. 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…
  2. 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…
  3. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023★ strong match
    …0 percent of the total value of all classes of stock of such corporation. For this purpose, section 958 (other than section 958(b)(1)) applies in determining ownership of a controlled foreign corporation and section 318(a) applies in determining ownership of other corporations, except that in applying section 318(a)(2)…
  4. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    period starts with the due date of the return. Sec. 6501(b)(1). - 13 - [*13] taxpayer signing the Form 4549 waives the section 6213(a) prohibition on the IRS's assessing a tax deficiency without the mailing of a notice of deficiency. S_e_e sec. 6213(d) (stating that taxpayers may waive restrictions on assessment provi…
  5. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
    IRCProposed Rules (FR)Proposed Sep 16, 2021
    … HHS and Transportation ability to conduct these analyses. E. Regulatory Flexibility Act The RFA (5 USC 601, et seq.), requires agencies to prepare an initial regulatory flexibility analysis to describe the impact of these proposed rules on small entities, unless the head of the agency can certify that the rule will no…
  6. 89 FR 84079 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCFinal Rules (FR)Oct 21, 2024related by meaning
    t to withholding under subchapter A of chapter 3 (sections 1441 through 1446 of the Code). 1. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the regulation treats an Army Post Office (APO), a Fleet Post Office (FPO), or a Diplomatic Post Office (DPO) [2] address as an a…
  7. 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 …
  8. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
  9. 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 …
  10. 79 FR 8544 — Shared Responsibility for Employers Regarding Health Coverage
    IRCFinal Rules (FR)Feb 12, 2014related by meaning
    t taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, 26 CFR parts 1, 54, and 301 are amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows:…
  11. 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 …
  12. T.D. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer …
    IRCTreasury DecisionsMay 23, 2016related by meaning
    April 28, 2016 (81 FR 25539). [3] See Hall v. United States, 566 U.S. ___, 132 S. Ct. 1882, 1893 (2012) (“[I]t is not for us to rewrite the statute.”) [4] Kirtsaeng is further inapposite because the statutory provisions of the Copyright Act that were compared to each other in that case (i.e., 17 U.S.C. § 109 and § 602)…
  13. T.C. Summary Opinion 2014-17 — Rebecca Smackey Hurd v. Commissioner
    IRCCourt RulingsFeb 25, 2014related by meaning
    …6, 398 (1984) ("Courts are not authorized to rewrite a statute because they might deem its effects susceptible of improvement."). While petitioner may perceive the result to be harsh, we cannot
  14. 76 FR 49570 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests
    IRCFinal Rules (FR)Aug 10, 2011
    …erest in the payments under the plan, determined as follows: (A) Present value of S 's annuity: $73,958.40 × 11.0625 = $818,164.80. (B) Annuity Factor for Expected Annuity Term: $818,164.80/$73,958.40 = 11.0625. (iii) The second step is to determine the number of years that would be required for S 's annuity to exhaust…
  15. 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…
  16. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024
    …0 percent of the total value of all classes of stock of such corporation. For this purpose, section 958 (other than section 958(b)(1)) applies in determining ownership of a controlled foreign corporation and section 318(a) applies in determining ownership of other corporations, except that in applying section 318(a)(2)…
  17. T.C. Memo. 2025-23 — Charlie Campana v. Commissioner
    IRCCourt RulingsMar 19, 2025related by meaning
    United States Tax Court T.C. Memo. 2025-23 CHARLIE CAMPANA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent __________ Docket No. 15766-23. Filed March 19, 2025. __________ Charlie Campana , pro se. Bianca L. Thomas and Daniel C. Munce, for respondent. MEMORANDUM FINDINGS OF FACT A ND OPINION PUGH , Judge : …
  18. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    IRCCourt RulingsJul 26, 1989related by meaning
    June 19, 1986, the Court of Appeals affirmed our decision sub nom. Dillon v. United States, 792 F.2d 849 (9th Cir. 1986). The parties also stipulated: Petitioners accept the determination of tax contained in the deficiency notice as mathematically correct, except they contend that the tax should be computed by applying…
  19. 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.
  20. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    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…