75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Jul 6, 2010related by meaning
to the transaction on or before the first date on which the transaction is required to be disclosed by the person under section 6011.
Special Analyses It has been determined that this Treasury decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not …
IRCCourt RulingsAug 13, 1990
hould prevail on the substantive issues as a matter of law. Rule 121(b); Naftel v. Commissioner, supra at 529; Espinoza v. Commissioner, supra at 416. Rule 121(d) provides that “an adverse party may not rest upon the mere allegations or denials of such party’s pleading, but such party’s response, by affidavits or as ot…
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCProposed Rules (FR)Proposed Mar 21, 2013
…, other than § 146.130 and the provisions with respect to genetic nondiscrimination (found in § 146.121(b), § 146.121(c), § 146.121(e), § 146.122(b), § 146.122(c), § 146.122(d), and § 146.122(e)) do not apply to any group health plan (and group health insurance coverage) for any plan year, if on the first day of the pl…
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…
IRCCourt RulingsSep 13, 1990
…on
(pre-ERTA)(500,000)(400,000)(300,000)
Taxable estate500,000 400,000 300,000
Tentative tax155,800 121,800 87,800
Unified credit121,800 121,800 121,800
Estate tax due34,000
Unused credit34,000
IRCCourt RulingsFeb 29, 2012related by meaning
Sav. Bank v. Salomon Smith Barney, Inc:, 530 U.S. 238, 254 (2000) (quoting
Hughes Aircraft Co. v. Jacobson', 525 U.S. 432, 438 (1999)). Similarly, the Supreme Court has stated that "where the language of an enactment is clear, and
construction according to its terms does not lead to absurd or impracticable
consequences…
89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction IRCProposed Rules (FR)Proposed Mar 25, 2024related by meaning
01:PR (REG-108761-22) room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Charles D. Wien of the Office of Associate Chief Counsel (Passthroughs & Special Industries), (202) 317-5279; concerning submissions…
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…
ERISAProposed Rules (FR)Proposed Nov 21, 2022related by meaning
therwise would be imposed and that meet the requirement of section IV C. of the exemption are not required to provide the notice.
Back to Citation
55. For materials and postage for paper notices. 242,956 notices × 41.8% paper notices × ($0.65 per paper notice)] = $66,011. Electronic notices will be distributed at de m…
78 FR 20039 — Reportable Events and Certain Other Notification Requirements PBGCProposed Rules (FR)Proposed Apr 3, 2013
…low-risk and high-risk entities. The burden for low-risk sponsors would go down from 417 hours and $121,725 to zero. The burden for high-risk sponsors
( printed page 20059)
would go up by approximately 760 hours and $157,100.
Low-risk
Volume
Hours
Cost
Current
144
417
$121,725
Proposed
0
0
$0
Change
(144)
(417)
(121,72…
90 FR 4192 — Voluntary Fiduciary Correction Program ERISAFinal Rules (FR)Jan 15, 2025
…(B)
(A × B)
(C)
(A × B × C)
(D)
(A × D)
Service providers prepare information (non-bulk)
326
2
652
$121.53
$79,238
$10.10
$3,293
Service providers prepare information (bulk)
2
20
40
121.53
4,861
10.10
20
Service providers maintain recordkeeping for SCC
909
0.17
152
121.53
18,412
Total
1,237
844
102,511
3,313
VFCP Class…
85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAProposed Rules (FR)Proposed Sep 4, 2020
…stration Office of Advocacy in making this determination, as required by 5 U.S.C. 603(c) and 13 CFR 121.903(c) in a memo dated June 4, 2020.
Back to Citation
116.
13 CFR 121.201 (2011).
Back to Citation
117.
15 U.S.C. 631
et seq.
(2011).
Back to Citation
118.
0.5 hours * $134.21 + 0.5 hours * $55.14 = $94.68.
Back t…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
is obtained on or before the date the IRS issues a notice of
deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74
…
83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCProposed Rules (FR)Proposed Dec 21, 2018
…a national bank or Federal savings association as a small entity.
Back to Citation
65.
See 13 CFR 121.201. Effective July 14, 2014, the SBA revised the size standards for banking organizations to $550 million in assets from $500 million in assets. 79 FR 33647 (June 12, 2014).
Back to Citation
66.
See 12 CFR part 21…
83 FR 46642 — Mergers and Transfers Between Multiemployer Plans PBGCFinal Rules (FR)Sep 14, 2018
…er plans and to improve the financial condition of PBGC's multiemployer insurance program. Sections 121 and 122 of MPRA provide that PBGC may assist financially troubled multiemployer plans under certain conditions.[1]
This rule is necessitated by section 121 of MPRA.
Section 121 of MPRA authorizes PBGC to facilitate m…
IRCCourt RulingsAug 6, 1991related by meaning
Petitioners’ third prong asserts that, in any event, the lump-sum payment and the annuity payments to which he was entitled came from separate accounts and that, consequently, the former payment was not received under an “annuity contract” so as to make section 72(e) applicable. Initially, we note that section 1.72-2(a…
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
…assets of the concern whose size is at issue and all of its domestic and foreign affiliates. 13 CFR 121.103(6).
Back to Citation
267.
13 CFR 121.201.
Back to Citation
268.
5 U.S.C. 601
et seq.
Back to Citation
269.
The SBA defines a small banking organization as having $600 million or less in assets, where “a financ…
85 FR 81658 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAFinal Rules (FR)Dec 16, 2020
120.
29 CFR 2509.2008-2 (73 FR 61731 (Oct. 17, 2008)).
Back to Citation
121.
EBSA estimates using 2018 Form 5500 filing data.
Back to Citation
122. The burden is estimated as follows: 63,911 plans * 0.5 hours = 31,955.4 hours for both a plan fiduciary and clerical staff. A labor rate of $134.21 is used for a plan f…
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…