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…
IRCCourt RulingsFeb 1, 2011
…560 F.2d 693, 696 (5th Cir.
1977) ("The tax collector's presumption of correctness has a
herculean muscularity of Goliathlike reach, but we strike an
Achilles' heel when we find no muscles, no tendons, no ligaments
of fact."). Petitioner concedes that he received wages,
interest, and pension and annuity income in 2004-…
IRCCourt RulingsApr 30, 2012
…resent any predicate evidence relating to this matter. See Portillo v.
Commissioner, 932 F.2d 1128, 1133 (5th Cir. 1991) (holding that "a court need
not give effect to the presumption of correctness in a case involving unreported
income if the Commissioner cannot present some predicate evidence supporting its
IRCCourt RulingsOct 23, 2006related by meaning
ng,
An appropriate decisio n
will be entered .
UNITED STATES TAX COURT
WASHINGTON , D .C . 20217-000 2
OFFICIAL BUSINESS
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IRCCourt RulingsJan 20, 1983
… dealing with the problem we face here. Compare BBS Associates, Inc. v. Commissioner, 74 T.C. 1118, 1133 (concurring opinion) (1980), affd. in an unpublished opinion (3d Cir. 1981).
IRCCourt RulingsApr 16, 2026
…cting the taxpayer with the
income-producing activity, see Portillo v. Commissioner, 932 F.2d 1128,
1133 (5th Cir. 1991), aff’g in part, rev’g in part and remanding T.C.
Memo. 1990-68, or demonstrate that the taxpayer actually received
income, Edwards v. Commissioner, 680 F.2d 1268, 1270– 71 (9th Cir.
IRCRegulationsJul 26, 2016related by meaning
(ii)(3) (3)
IRCCourt RulingsJun 23, 2025
…g the taxpayer with the income -
pro ducing activity, see Portillo v. Commissioner , 932 F.2d 1128, 1133
(5th Cir. 1991), aff’g in part, rev’g in part and remanding T.C. Memo.
1990- 68, or demonstrate that the taxpayer actually received income, Edwards v. Commissioner, 680 F.2d 1268, 1270– 71 (9th Cir. 1982) (per curia…
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 RulingsJun 6, 2019
…stablish "some factual foundation" for the assessment, see Portillo v.
Commissioner, 932 F.2d 1128, 1133 (5th Cir. 1991), aff'g in part, rev'g in part
T.C. Memo. 1990-68; Carson v. United States, 560 F.2d 693, 696 (5th Cir. 1977).
Petitioner concedes that she received her ERS distribution in 2010. Consequently,
the pre…
IRCCourt RulingsAug 13, 1990related by meaning
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968
…ming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (1957), relied upon by petitioner, are clearly distinguishable on their facts.
I.R.C. § 6701(c) — Penalties for aiding and abetting understatement of tax liability IRCCode / StatuteJan 4, 1995related by meaning
(c) (c) Activities of subordinates
(c)(1) (1) In general For purposes of subsection (a), the term "procures" includes—
(c)(1)(A) (A) ordering (or otherwise causing) a subordinate to do an act, and
(c)(1)(B) (B) knowing of, and not attempting to prevent, participation by a subordinate in an act.
(c)(2) (2) Subordinate F…
ERISACode / StatuteJan 6, 2017
…redress of claims which are denied in whole or in part (including procedures required under section 1133 of this title), and if the employer so elects for purposes of complying with section 1181(f)(3)(B)(i) of this title, the model notice applicable to the State in which the participants and beneficiaries reside.
86 FR 66662 — Prescription Drug and Health Care Spending IRCFinal Rules (FR)Nov 23, 2021related by meaning
notice that a provider, facility, or provider of air ambulance services has initiated the Federal IDR process, upon sending or receiving such notice. (2) The Director will coordinate with the Departments in resolving matters under 26 CFR 54.9816-8T(c)(4)(vii)(A)(
1), 29 CFR 2590.716-8(c)(4)(vii)(A)(
1), or 45 CFR 149.…
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
om tax under section 897(l), regardless of the amount of unrealized gain in Property A as of November 1, 2016.
(f)
Applicability date
—(1)
In general. Except as otherwise provided in paragraph (f)(2) of this section, this section applies to a disposition of a United States real property interest, or a distribution desc…
78 FR 13797 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements ERISAFinal Rules (FR)Mar 1, 2013
…uthority citation for part 2560 is revised to read as follows:
Authority:
29 U.S.C. 1002(40), 1132, 1133, 1134, 1135, and 1151; and Secretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012).
2. Sections 2560.521-1 through 2560.521-4 are added to read as follows:
§ 2560.521-1
Cease and desist and seizure orders under…
85 FR 39831 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA; Correction ERISAFinal Rules (FR)Jul 2, 2020
… of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012). Section 2560.503-1 also issued under 29 U.S.C. 1133. Section 2560.502c-7 also issued under 29 U.S.C. 1132(c)(7). Section 2560.502c-4 also issued under 29 U.S.C. 1132(c)(4). Section 2560.502c-8 also issued under 29 U.S.C. 1132(c)(8).
T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409… IRCTreasury DecisionsJan 18, 2005related by meaning
INCOME TAX
Rev. Rul. 2005-3 Rev. Rul. 2005-3
Section 901(j)(5) Presidential waiver; Libya. Pursuant to a section 901(j)(5) Presidential waiver, section 901(j)(1) of the Code ceased to apply to Libya effective December 10, 2004. Section 911(d)(8) is not applicable to Libya after September 20, 2004, and Iraq after July 2…
85 FR 31884 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAFinal Rules (FR)May 27, 2020
… of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012). Section 2560.503-1 also issued under 29 U.S.C. 1133. Section 2560.502c-7 also issued under 29 U.S.C. 1132(c)(7). Section 2560.502c-4 also issued under 29 U.S.C. 1132(c)(4). Section 2560.502c-8 also issued under 29 U.S.C. 1132(c)(8).
6. Amend § 2560.503-1 by revising …