34 T.C. 851 — West Virginia Steel Corp. v. Commissioner IRCCourt RulingsAug 15, 1960related by meaning
n this report.
All statutory references herein are to the Internal Revenue Code of 1939, unless otherwise specified.
SEC. 291. FAILURE TO PILE RETÜRN. (a) In ease of any failure to make and file return required by this chapter, -within the time prescribed by law or prescribed by the Commissioner in pursuance of law, un…
IRCCourt RulingsSep 24, 2026related by meaning
e age of
59 1/2 during 2021. And he does not c on tend that any of the other exceptions in section 72(t)(2 ) applies . We will accordingly sustain the IRS’s determination of a $ 22,986 additional tax for 2021.
IV. Penalty
The Code imposes a 20% penalty upon the portion of any underpayment of income tax required to be s…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCPrivate Letter RulingsApr 30, 2010
… April 01, 2010 2:59:47 PM
To: ------------------
Cc:
Subject: RE: ERISA question
The pr ovision 29 USC 1104(b) that you are referring to is section 404(b) of ERISA, that provides that
no fiduciary may maintain the indicia of ownership of any assets of a plan outside the jurisdiction of the
District Courts of the U.S.,…
IRCCourt RulingsJan 6, 1997related by meaning
etitioners are liable for an
accuracy-related penalty of $4,870 pursuant to section 6662(a)
for 1991. Section 6662 imposes a 20-percent penalty on any portion of any underpayment that is attributable to any
substantial understatement of income tax. Sec. 6662(a)(2),
- 14 -
(b)(2). Respondent based the determination of t…
78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-… IRCFinal Rules (FR)Nov 13, 2013
…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.
List of Subjects
26 CFR Part 54
Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590
Continuation c…
PBGCPBGC Opinion LettersSep 30, 1994
…( 4)( B)>
421 9 N otice & Co llection o f W ithdraw al Liab ility
422 1 Reso lution of Disputes
>29 USC 1461 n ote >
OP INI ON :
I
wri te i n res ponse t o your reque st for the opini on
of the Pension Benefit Guaranty Corporation ("PBG C").
Your
fir st r equest c oncerns a par ticu lar
applicat ion of t he princ iples…
IRCCourt RulingsFeb 9, 1998related by meaning
ed his name and Social
Security number on the forms and signed each of them. As a part
of the address, petitioner identified his country as "Arkansas, USA". The second set of Forms 1040NR contained "NONE" or "N/A"
in pertinent spaces. On line 23 of the forms, petitioner
reported that he received $65,000 in income that …
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…
75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient… IRCFinal Rules (FR)Jul 23, 2010
…ing Department of Labor claims procedure regulation. That is, the Department of Labor interprets 29 USC 1133 and the DOL claims procedure regulation as already requiring that plans provide claimants with new or additional evidence or rationales upon request and an opportunity to respond in certain circumstances.
See
Br…
IRCCourt RulingsJun 6, 2016related by meaning
racy-related penalty under section
6662(a) and (b)(2) for an underpayment due to a substantial understatement
of income tax for the 2011 taxable year. Section 6662(a) imposes a 20% "accuracy-related penalty" on an
underpayment of tax attributable to any of the causes listed in section 6662(b).
These causes include "[a]…
75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections IRCFinal Rules (FR)Jun 28, 2010
… read as follows:
Authority:
2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
5. Add § 147.108 to read as follows:
§ 147.108
Prohibition of preexisting condition exclusions.
(a)
No preexisting condition exclusions
—(1)
In general.
A …
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…the No Surprises Act.
U.S.C.-Brookings Schaeffer on Health Policy.
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/03/16/recommendations-for-implementing-the-no-surprises-act/.
Back to Citation
340.
See,
for example, the proposed 2027 HHS notice of benefit and payment parameters (9…
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…
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…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
87 FR 80042 — Exception for Interests Held by Foreign Pension Funds IRCFinal Rules (FR)Dec 29, 2022related by meaning
ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development.
( printed page 80055) List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended a…
IRCCourt RulingsFeb 25, 2016related by meaning
4. Respondent has allowed exactly those amounts as deductions for 2004
and 2005. Petitioner has made no attempts to provide the Court with evidence of any other payments for travel and meals and entertainment expenses. With the
heightened substantiation requirements under section 274 and the lack of
additional document…
IRCCourt RulingsNov 18, 2021related by meaning
uch before they were placed in the safe. We question whether labeling
is sufficient to satisfy the Code’s prohibition against com m ingling or whether storage in a safe satisfies the requirem ent that assets requiring safekeeping be kept
in an adequate vault. However, we do not need to resolve this issue as Mrs.
McNult…
IRCCourt RulingsMar 3, 2016related by meaning
n the return of the
relevant facts affecting the item's tax treatment and there is a reasonable basis for
the taxpayer's treatment of the item.
- 10 - [*10] Here, the understatement of income tax is greater than $5,000. Thus, the
understatement is substantial for purposes of the section 6662(a) accuracy-related
penalty…