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 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 : …
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
utes] × $63.45 = $793.
Back to Citation
65.
5 U.S.C. 601
et seq.
Back to Citation
66.
5 U.S.C. 601(2), 603(a);
see5 U.S.C. 551.
Back to Citation
67. Public Law 104-4, 109 Stat. 48 (Mar. 22, 1995).
Back to Citation
68.
Reorganization Plan No. 4 of 1978 (5 U.S.C. App. 1 (2018)) generally transferred the authority of …
IRCCourt RulingsDec 18, 2012
…determination as to the abatement of interest. See sec. 6404(h); Rule 280(b); Gati
v. Commissioner, 113 T.C. 132, 134 (1999); Bourekis v. Commissioner, 110 T.C.
at 25-26.
-
78
-
[*78]
APPENDIX
SUMMARY
OF
RESPONDENT'S
BANK
DEPOSITS
ANALYSES
1992
Ms.
Zaklama
BOA3886
FFB2740
Total
Deposits
$66,985
$483,616
$550,601
Less:
…
T.D. 9836 — These final regulations provide guidance regarding substantiation and reporting requirements for cash and noncash charitable contributions. The final regulatio… IRCTreasury DecisionsAug 13, 2018related by meaning
602.101 OMB Control numbers.
* * * * *
(b) * * *
______________________________________________________________
CFR part or section where Current OMB identified and described control No.
* * * * *
1.170A–15. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . …
IRCCourt RulingsJan 2, 2025related by meaning
ively , petitioners are liable for a section 6662 accuracy -
related penalty. We hold Mr. Hutcheson is liable for the fraud
penalty .
FINDINGS OF FACT W hen the Petition was timely filed , Mrs. Hutcheson resided in
Idaho , and Mr. Hutcheson was incarcerated in California .
3
Some facts
and exhibits have been deemed sti…
81 FR 47534 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Jul 21, 2016
…L. 112-141); the Cooperative and Small Employer Charity Pension Flexibility Act (CSEC Act) (Pub. L. 113-98); the Highway and Transportation Funding Act (HATFA) (Pub. L. 113-159); the Multiemployer Pension Reform Act of 2014, Division O of the Consolidated and Further Continuing Appropriations Act, 2015, (Pub. L. 113-23…
76 FR 13932 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations IRCProposed Rules (FR)Proposed Mar 15, 2011related by meaning
ice (IRS) under section 6104(c).
DATES:
Written or electronic comments and requests for a public hearing must be received by June 13, 2011.
ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-140108-08), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be han…
Notice 2022-8 — The notice sets forth the 2022 Cumulative List of Changes in Section 403(b) Requirements for Section 403(b) Pre-approved Plans (2022 Cumulative List). The 2022… IRCNoticesFeb 14, 2022
…us as a section 403(b)(7) custodial account. e. Qualified Birth or Adoption Distributions
• Section 113 of the SECURE Act amends section 72(t)(2) of the Code to add a new exception to the 10-percent additional tax for any qualified birth or adoption distribution. An individual generally may recontribute a qualified bir…
Notice 2015-84 — The Notice provides a list of changes in plan qualification requirements to be used by plan sponsors submitting determination letter applications for plans dur… IRCNoticesDec 28, 2015
…12 (ATRA), Pub. L. 112–240; the Highway and Transportation Funding Act of 2014 (HATFA), Pub. L. No. 113–159; the Cooperative and Small Employer Charity Pension Flexibility Act (CSEC Act), Pub. L. 113–97; the Consolidated and Further Continuing Appropriations Act, 2015, Pub. L. No. 113–235; and the Surface Transportatio…
IRCCourt RulingsMay 30, 1984related by meaning
ents of section 2039(c)(3).
Due to concessions and in order to reflect petitioner’s claim for an overpayment,
Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
REG-108641-14 — This document solicits comments from the public on provider nondiscrimination prohibited under section 2706 of the Public Health Service Act. Comments must be … IRCProposed Rules (FR)Proposed Apr 7, 2014
…://www.cms.gov/CCIIO/Resources/Fact-Sheets-and-FAQs/aca_implementation_faqs15.html.
[3] S. Rep. No. 113–71, at 126 (2013).
[4] S. Rep. No. 113–71, at 126 (2013). Additionally, in Title I of the report, regarding the Department of Labor Employee Benefits Security Administration, the Committee “directs the Department to …
89 FR 104915 — Regulations Governing Practice Before the Internal Revenue Service IRCProposed Rules (FR)Proposed Dec 26, 2024related by meaning
in § 10.82.
* * * * *
(d) This section is applicable beginning on [date 30 days after date of publication of final regulations in the
Federal Register ].
Par. 37.
Newly redesignated § 10.85 is amended by:
1. Revising paragraph (a)(2).
2. Adding paragraph (a)(3).
3. Revising paragraph (c).
The revisions and addition rea…
88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation
52.
5 U.S.C. 601
et seq.
Back to Citation
53.
5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551.
Back to Citation
54.
Public Law 104-4, 109 Stat. 48 (Ma…
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…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016related by meaning
note, Pub. L. 114-74 at § 701. Subparts H and I issued under 8 U.S.C. 1101(a)(15)(H)(i)(b) and (b1), 1182(n), 1182(t), and 1184; 29 U.S.C. 49
et seq.; sec 303(a)(8), Pub. L. 102-232, 105 Stat. 1733, 1748 (8 U.S.C. 1182 note); and Title IV, Pub. L. 105-277, 112 Stat. 2681; and 28 U.S.C. 2461 note, Pub. L. 114-74 at § 70…
IRCCourt RulingsJul 29, 2003related by meaning
96, petitioner made an
estimated tax payment for 1996 of $2,000
9
and that petitioner
made no estimated tax payments for 1997.
10
On the record before us, we find that respondent has satisfied respondent’s burden of
- 10 -
production with respect to the additions to tax under section
6654(a) for the years at issue. On …
IRCCourt RulingsJul 5, 2011related by meaning
." Sec. 6011(a). The addition to tax will not
apply if it is shown that such failure is due to reasonable cause
and not due to willful neglect.
- 21 - Taxpayers ho have made excess contributions to an IRA are
required to file Form 5329 each year that they have 'excess
contributions. Hellweg v. Commissioner, T.C. Memo.'…
IRCCode / StatuteJan 5, 2023related by meaning
(d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and
(d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer.
(d)(2)(C) (C) Reduction not to apply to tax shelters
(d)(…
IRCCourt RulingsJan 17, 2024related by meaning
ies.
Subchapter C, consisting solely of section 6751, sets forth “Procedural
Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides
evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…