89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
Misconduct under Section III(a)(2) while adding protections to the exemption by conditioning disqualification on determinations in court proceedings. Ineligibility under amended Section III(a)(2) will result from a Financial Institution or an Investment Professional being found in a final judgment or court-approved set…
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…
IRCCourt RulingsJun 17, 1997
…le 4/40 4/40 4/40 4/40
Normal retirement age Same as 401(a) Same Same Same
Death benefit multiple 4.122 2.692 4.122 4.122
Date executed 07/31/90 07/31/90 07/30/91 10/01/91
D. Administration of N.L. Booth's Account in the Prime Plan
On August 12, 1991, IFTI forwarded the 1990 annual report
for N.L. Booth's account in th…
IRCCourt RulingsFeb 12, 2014
…elvering,
290 U.S. 111, 115 (1933); ci secs. 6201(d), 7491(a).3 The submission of a case
under Rule 122 does not alter the taxpayer's burden of proof. Rule 122(b); see
Borchers v. Commissioner, 95 T.C. 82, 91 (1990), aff'd, 943 F.2d 22 (8th Cir.
1991).
As presented by the parties and on the basis of the stipulated fact…
IRCCourt RulingsAug 27, 2018related by meaning
arguments to justify them. We therefore hold that petitioner
- 10 -
[*10] is liable for the penalty for an underpayment attributable to a substantial understatement of income tax under section 6662(a) and (b)(2) for each year.
V. Section 6673 Sanction
Respondent moved that the Court impose sanctions against petitioner…
IRCCourt RulingsApr 2, 2020
taxpayer in a CDP hearing can challenge the liability for interest. Urbano
v. Commissioner, 122 T.C. 384, 390 (2004); Montgomery v. Commissioner, 122 T.C. 1, 8 (2004). A challenge to liability for interest can be premised on the
interest-abatement provisions of section 6404(e)(1). See Urbano v.
Commissioner, 122 T.C. …
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
er 1 as determined under subsection (e)
by substituting —
(i) in paragraph (1)(A), “200 percent”
for “150 percent” . . . .
2. Section 6662: Discussion Section 6662(a) is a generally applicable provision through which
all accuracy-related penalties are imposed on underpayments of tax.
Section 6662(b) lists the penalizab…
84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b) IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
Pensions
Railroad retirement
Reporting and recordkeeping requirements
Social security
Unemployment compensation
Proposed Amendments to the Regulations Accordingly, 26 CFR part 31 is proposed to be amended as follows:
PART 31—EMPLOYMENT TAXES AND COLLECTION OF INCOME AT THE SOURCE
Paragraph 1.
The authority citation for…
IRCProposed Rules (FR)Proposed Dec 24, 2013
…
Public Law 104-204, 110 Stat. 2944 (September 26, 1996).
Back to Citation
2.
Public Law 110-343, 122 Stat. 3881 (October 3, 2008).
Back to Citation
3.
Public Law 104-204, 110 Stat. 2935 (September 26, 1996).
Back to Citation
4.
Public Law 105-277, 112 Stat. 2681-436 (October 21, 1998).
Back to Citation
5.
Public …
Joint BoardRegulationsDec 30, 2016related by meaning
(b) (b) Depositions upon oral examination
(b)(1) (1) A deposition must be taken before an officer duly authorized to administer an oath for general purposes or before an officer or employee of the Internal Revenue Service who is authorized to administer an oath in Federal tax law matters.
(b)(2) (2) In ordering a depos…
Joint BoardRegulationsDec 30, 2016related by meaning
(d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved.
(d)(4)(iv) (iv) Public i…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
IRCFinal Rules (FR)Aug 3, 2018
…
Public Law 104-204, 110 Stat. 2944 (September 26, 1996).
Back to Citation
3.
Public Law 110-343, 122 Stat. 3881 (October 3, 2008).
Back to Citation
4.
Public Law 104-204, 110 Stat. 2935 (September 26, 1996).
Back to Citation
5.
Public Law 105-277, 112 Stat. 2681-436 (October 21, 1998).
Back to Citation
6.
Public …
83 FR 7437 — Short-Term, Limited-Duration Insurance IRCProposed Rules (FR)Proposed Feb 21, 2018
…
Public Law 104-204, 110 Stat. 2944 (September 26, 1996).
Back to Citation
3.
Public Law 110-343, 122 Stat. 3881 (October 3, 2008).
Back to Citation
4.
Public Law 104-204, 110 Stat. 2935 (September 26, 1996).
Back to Citation
5.
Public Law 105-277, 112 Stat. 2681-436 (October 21, 1998).
Back to Citation
6.
Public …
IRCProposed Rules (FR)Proposed Dec 23, 2014
…
Public Law 104-204, 110 Stat. 2944 (September 26, 1996).
Back to Citation
2.
Public Law 110-343, 122 Stat. 3881 (October 3, 2008).
Back to Citation
3.
Public Law 104-204, 110 Stat. 2935 (September 26, 1996).
Back to Citation
4.
Public Law 105-277, 112 Stat. 2681-436 (October 21, 1998).
Back to Citation
5.
Public …
79 FR 51092 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Aug 27, 2014
…nt with the analysis in the HHS PRA section above the Department expects that each of the estimated 122 organizations will spend approximately 50 minutes in preparation time and incur $0.54 mailing cost to satisfy the requirements. The DOL information collections in this rule are found in 29 CFR 2510.3-16 and 2590.715-…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
81 FR 47534 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Jul 21, 2016
…g. 21, 1996); Title I of the Genetic Information Nondiscrimination Act of 2008, Public Law 110-233, 122 Stat. 881 (May 21, 2008); the Mental Health Parity Act of 1996, Public Law 104-204, 110 Stat. 2944 (Sept. 26, 1996) and the Mental Health Parity and Addiction Equity Act of 2008, Public Law 110-343, 122 Stat. 3881 (O…
IRCFinal Rules (FR)Mar 18, 2015
…
Public Law 104-204, 110 Stat. 2944 (September 26, 1996).
Back to Citation
2.
Public Law 110-343, 122 Stat. 3881 (October 3, 2008).
Back to Citation
3.
Public Law 104-204, 110 Stat. 2935 (September 26, 1996).
Back to Citation
4.
Public Law 105-277, 112 Stat. 2681-436 (October 21, 1998).
Back to Citation
5.
Public …
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
…