Rev. Proc. 2005-76 — Retroactive payment of benefits; multiemployer plan; discretionary relief; extension. This procedure extends the date by which certain qualified retirement pla… IRCRevenue ProceduresDec 12, 2005
…e eligible for the treatment described in section 3.02 of Revenue Procedure 2005-23, 2005-18 I.R.B. 991, relating to the Supreme Court decision in Central Laborers’ Pension Fund v. Heinz, 541 U.S. 739 (2004).
SECTION 2. BACKGROUND
IRCCourt RulingsJan 5, 2017related by meaning
ccuracy-related penalty under
section 6662.
OPINION
I. Preliminary Matters
Petitioner argues that respondent bears the burden of proof with respect to his unreported income for both tax years. For the reasons below, we disagree.
Generally, the Commissioner's determinations in a notice of deficiency are
presumed correct…
IRCCourt RulingsFeb 4, 1998related by meaning
ent under section 6654; and
(4) whether petitioner is liable for a penalty under section
6673. We hold for respondent on all issues. We also hold that petitioner is liable for a penalty under section 6673 and require
him to pay to the United States a penalty of $5,000. Unless
otherwise stated, section references are to…
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…
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
IRCCourt RulingsMar 9, 2011related by meaning
ds of thousands of dollars
in DISC commissions each year from a well-established business,
and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount.
-28IV. Section 6662(a) Penalty
Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
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 9, 1998related by meaning
… badges of fraud. Accordingly, petitioner is liable
for section 6651(f) additions to tax for 1990, 1991, and 1992. Section 6654(a) imposes an addition to tax for failure to
make timely estimated income tax payments. Where prepayments of
tax do not equal the percentage of total liability required to be
- 19 -
paid as es…
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 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…
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 RulingsMar 5, 2018
…as used in these cases.4¹ Individual
4¹DISCs are U.S. corporations electing to be taxed under secs. 991-997.
Secs. 991-997 were enacted in 1971 and substantially modified in 1984 by the
same act that introduced FSCs to the Code. See Deficit Reduction Act of 1984,
Pub. L. No. 98-369, secs. 801-805, 98 Stat. at 985-1003;…
IRCCourt RulingsJul 24, 1996
…tment. This amount was then multiplied by the
remaining length of each contract to arrive at $3,210,991.
- 8 -
None of petitioner's collective bargaining agreements
required use of a welfare benefit fund or prefunding of the
negotiated benefits. Petitioner's 1987 contribution included
$3,210,991 for union medical benef…
IRCCourt RulingsJan 19, 2010related by meaning
JOHN C . . A MBRUST, Petitioner v .
COMMISSTONEROF INTERNAL 'REVENUE, Responden t
.° Filed .' January` "19, 2010 .
GOLDBERG , Specia l Trial" Judge : ,' This case w as heard-pursuant
to the provision ` s of secti n6 7463 of' .the Internal Revenue Code i n
effect at the time the {pet'tion was filed . Pursuant ' to '-sec…
IRCCourt RulingsApr 12, 1979
…R. Latterman . 2,189.20 10 months
J. Hernandez . 1,002.00 2 months
B. Redden . 1,283.75 10 months
5,991.45
All four of the above individuals terminated their employment with petitioner prior to the end of petitioner’s taxable year. Their total compensation of $5,991.45 was used in determining the 15-percent limitation …
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 RulingsMar 24, 1959
…r renegotiation Renegotiate Nonrene-gotiable Total Sales.. Net profit... Percentage.. $527,637 $150,991 28.61* i $16,490 $4,764 28.8 $544,127 $155,755 28.6 $432,637 $55, 991 12.9 $16,490 $4,764 28.8 $449,127 $60,755 13.5 1 Of this amount $16,054 represented sales of salted peanuts to the corporation and its subsidiary.…
IRCCourt RulingsSep 24, 2007related by meaning
trates actual knowledge by
petitioner of the . IRA distribution, at the time she signed th e
6 The five criteria of sec . 6015(b)(1) are conjunctive . Having concluded that sec . 6015(b)(1)(C) is not satisfied, we
need not, and do not, discuss the criteria of the other
subsections of sec . 6015(b)(1) .
- 11 -
return . …
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.
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…