88 FR 1991 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 12, 2023
…ORMATION
1. The authority citation for part 4071 continues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, remove the number “$2,400” and add in its place the number “$2,586”.
PART 4302—PENALTIE…
84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b) IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
ies as taxpayers who are living abroad. Johnny C. Finch,
United States Citizens Living in Foreign Countries and Not Filing Federal Income Tax Returns, United States General Accounting Office, May 8, 1985. In addition, enforcement of compliance by individuals receiving mail at an APO, FPO, or DPO address generally does …
87 FR 2340 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 14, 2022
…ORMATION
1. The authority citation for part 4071 continues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, remove the number “$2,259” and add in its place the number “$2,400”.
PART 4302—PENALTIE…
PBGCRegulationsJan 1, 2017related by meaning
(c) (c) Where to file. See § 4000.4 of this chapter for information on where to file.
IRCCourt RulingsAug 27, 2018related by meaning
arguments to justify them. We therefore hold that petitioner
- 10 -
[*10] is liable for the penalty for an underpayment attributable to a substantial understatement of income tax under section 6662(a) and (b)(2) for each year.
V. Section 6673 Sanction
Respondent moved that the Court impose sanctions against petitioner…
PBGCFinal Rules (FR)Sep 22, 2022related by meaning
ned that this action is not a “significant regulatory action” under the criteria set forth in Executive Order 12866.
List of Subjects
29 CFR Part 4000 Administrative practice and procedure
Pension insurance
29 CFR Part 4233
Employee benefit plans
Pension insurance
Reporting and recordkeeping requirements
29 CFR Part 49…
PBGCFinal Rules (FR)Jul 25, 2022related by meaning
services (or in the case of a requester described under section 552(a)(4)(A)(ii)(II), for duplication) if one of the following circumstances applies: (1) PBGC has determined that unusual circumstances (as defined in section 552(a)(6)(B) of FOIA) apply, PBGC needs more than 10 additional days to process the disclosure …
IRCCourt RulingsAug 8, 2000related by meaning
respondent determined that all
the IRA distributions from Fidelity for the 1996 taxable year
were includable in gross income and therefore included an additional $6,905 of 1996 IRA distributions from Fidelity in
petitioner’s 1996 gross income.
Tax Court Jurisdiction
First, petitioner contends that the order of Discharg…
IRCCourt RulingsMar 3, 2016related by meaning
, petitioner tried to keep his tax records and IRS paperwork
for 10 years.
In 2001 petitioner ran a small pharmacy in addition to working at a Federal Government hospital. On April 19, 2001, he was charged, along with two other
codefendants, with diversion of pharmaceuticals from the Department of Veterans
Affairs, and…
IRCCourt RulingsJan 2, 2020related by meaning
er. Mrs. Gebman did not provide any evidence that persuades us that
she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file
amendment to petition filed August 28, 2019.
VI. Section 6662(a) Penalties
Section 6662(a) an…
PBGCFinal Rules (FR)May 13, 2016
…RMATION
5. The authority citation for part 4071 is revised to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
6. In § 4071.3, the figures “$1,100” are removed and the figures “$2,063” are added in their place.
( p…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
IRCCourt RulingsFeb 1, 2011related by meaning
ximum sanction under
section 6673(a) (1) is appropriate. We shall require petitioner
to pay a $25,000 penalty under section 6673(a) (1) in each of the consolidated cases.
V. Conclusion
We conclude that (1) petitioner is liable for a reduced
deficiency and additions to tax for 20Ø4 as respondent conceded,
and (2) petiti…
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
property and withholding agents that are required to withhold tax on certain dispositions of, and distributions with respect to, such property.
DATES: Written or electronic comments and requests for a public hearing must be received by September 5, 2019.
ADDRESSES:
Send submissions to: CC:PA:LPD:PR (REG-109826-17), Int…
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 RulingsDec 28, 2000related by meaning
filed a voluntary petition
for reorganization under chapter 11 of the Bankruptcy Code (the
bankruptcy case). In the bankruptcy case, the Commissioner asserted a section 4971 deficiency against the company for
- 4 -
failure to satisfy the minimum funding standard pursuant to
section 412.
In 1994, petitioner was indicte…
IRCCourt RulingsJun 14, 2012related by meaning
atement for any taxable year, there shall be added to the tax an amount
equal to 20% of the amount of such understatement." The penalty applies to any deficiency which is attributable to any listed transaction or any reportable
transaction if a significant purpose of the transaction is the avoidance or evasion
- 41 -
o…
85 FR 2304 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 15, 2020
…ORMATION
1. The authority citation for part 4071 continues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, the figures “$2,194” are removed and the figures “$2,233” are added in their place.
PAR…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016related by meaning
................................................ 494
.08 Penalty of perjury statement ............................................................ 494 .09 Procedural Requirements Checklist . . .. . .. . .. . .. . .. . .. . ......................... 494
.10 Orphan Plan ... . .. . .. . .. . .. . .. . .. . .. . .. . .. . …
91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information PBGCProposed Rules (FR)Proposed Jul 21, 2026
…
Mitigating factors.
4071.26
Other circumstances.
4071.27
Aggravating factors.
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
Subpart A—Purpose and Definitions
§ 4071.1
Purpose and scope.