Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026
…t applicable provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (FCAA), known as the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), section 104 of Division M of the FCAA, known as the Bipartisan American Miners Act of 2019 (Mine…
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…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
ns
were made negligently or intentionally.”) (emphasis added);
see Mathews
v.
Chevron Corp.,
362 F.3d 1172, 1183 (9th Cir. 2004).
Back to Citation
37. 84 FR 33348, note 303. The Department observes that this requirement is also consistent with, for example, the requirement under section 206 of the Advisers Act, which …
T.C. Memo. 2017-77 — Estate of Hung-Liang Lynn Lin, Deceased, Jeffrey S. Lin, Administrator v. Commissioner IRCCourt RulingsMay 8, 2017
…taxpayer acted in good faith with respect to such portion.
Sec. 6664(c)(1); Higbee v. Commissioner, 116 T.C. at 446-447. The
determination of whether the taxpayer had reasonable cause and acted in good
faith depends upon the pertinent facts and circumstances of a particular case. Sec.
1.6664-4(b)(1), Income Tax Regs. W…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner IRCCourt RulingsDec 13, 2018
…le, they had reasonable cause and acted in good faith. See sec. 6664(c)(1); Higbee v.
Commissioner, 116 T.C. at 446-447.
The determination whether the taxpayer had reasonable cause and acted in
good faith depends upon the pertinent facts and circumstances of a particular case.
Sec. 1.6664-4(b)(1), Income Tax Regs. We c…
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…
IRCCourt RulingsJan 28, 2014
…spect to
any penalty, including the accuracy-related penalty. Sec. 7491(c); Hiebee v.
Commissioner, 116 T.C. 438, 446 (2001). To meet that burden, the Commissioner
must come forward with sufficient evidence indicating that it is appropriate to
impose the relevant penalty. Hiebee v. Commissioner, 116 T.C. at 446. Howeve…
IRCCourt RulingsJan 2, 2020related by meaning
… the burden of production with respect
to the accuracy-related penalty. See Higbee v. Commissioner, 116 T.C. at 446.
To satisfy the burden of production under section 7491(c), respondent must
IRCCourt RulingsOct 25, 2006
return, petitioner properly
reported the $116,251 .20 distribution as income but did not
report the 10-percent additional tax for early distributions under section 72(t) . In the notice of deficiency, respondent
determined that petitioner was liable for the 10-percent
additional tax on the early $116,251 .20 distribut…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018related by meaning
18071, 18082, 26 U.S.C. 36B, and 31 U.S.C. 9701); and Public Law 103-141, 107 Stat. 1488 (42 U.S.C. 2000bb-2000bb-4).
List of Subjects
26 CFR Part 54 Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590
Continuation coverage
Disclosure
Employee benefit plans
Grou…
IRCCourt RulingsSep 1, 2016
…,
the Commissioner bears the burden of production with regard to penalties. Higbee
v. Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner has met the
burden of production, the taxpayer has the burden of proving that the penalties are
9Petitioner's annuity contract was a qualified individual retirement annuity…
Notice 2026-9 — This notice provides guidance relating to amendments under section 501 of the SECURE 2.0 Act of 2022 for individual retirement arrangements and annuities (IRAs… IRCNoticesFeb 9, 2026related by meaning
igibility to represent taxpayers before the IRS in examinations of tax returns the preparer both prepared for the taxpayer and signed as the preparer. Additionally, unenrolled/unlicensed return preparers who participate in the AFSP agree to be subject to the duties and restrictions in Circular 230, including the restri…
IRCCourt RulingsJan 3, 2017
is
appropriate. See sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446
(2001). Once the Commissioner meets his burden of production, the taxpayer bears the burden of proving, through persuasive evidence, that the
Commissioner's penalty determination is incorrect. See Rule 142(a); Welch v.
Helvering, 290 U.S. 111, …
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…
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.
IRCCourt RulingsAug 10, 2015
…, the Commissioner bears the burden of production with regard to
penalties. Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Once the
Commissioner has met the burden of production, the taxpayer has the burden of
proving that the penalties are inappropriate because of reasonable cause or
substantial authority. See Rule…
Notice 2024-82 — This notice sets forth the 2024 Required Amendments List (2024 RA List). The 2024 RA List applies to individually designed plans qualified under section 401(a)… IRCNoticesDec 23, 2024
…f 2022 (SECURE 2.0 Act).
3 Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (2019).
4 Pub. L. 116-136, 134 Stat. 281 (2020).
5 Division EE of the Consolidated Appropriations Act, 2021, Pub. L. 116-260, 134 Stat. 1182 (2020).
6 Section G of Notice 2020-68, 2020-38 IRB 567, …
Joint BoardRegulationsDec 30, 2016related by meaning
(a)(5) (5) Solicitation of employment as prohibited under § 10.30, the use of false or misleading representations with intent to deceive a client or prospective client in order to procure employment, or intimating that the practitioner is able improperly to obtain special consideration or action from the Internal Reven…
Notice 2022-33 — Notice 2022-33 extends the deadlines for amending a retirement plan or IRA to reflect the provisions of Division O of the Further Consolidated Appropriations A… IRCNoticesAug 22, 2022
…lect certain provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (2019), known as the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), and section 104 of Division M of the Further Consolidated Appropriations Act, 2020, known as the…