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55 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 89 FR 102735 — Disclosure of Records
    IRCFinal Rules (FR)Dec 18, 2024related by meaning
    …, all remaining provisions shall continue in effect. IV. Procedural Requirements A. Executive Order 12866 This rule is not a significant regulatory action as defined in E.O. 12866, dated September 30, 1993, as amended, and is not a major rule under 5 U.S.C. 804. B. Administrative Procedure Act (APA) Because this rule r…
  2. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025related by meaning
    Memo. 2002-18, 83 T.C.M. (CCH) 1107 , 1108– 10 (imposing penalty of $2,000 under section 6673(a)), af f’ d , 54 F. App ’ x 254 (9th Cir. 2002) ; s ee G reat - West Life Assurance Co. v. United States , 678 F.2d 180, 183 ( Ct. Cl. 1982) (“The determination of where income is derived or ‘sourced’ is generally of no mome…
  3. 79 FR 8544 — Shared Responsibility for Employers Regarding Health Coverage
    IRCFinal Rules (FR)Feb 12, 2014related by meaning
    t taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, 26 CFR parts 1, 54, and 301 are amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows:…
  4. 82 FR 12319 — Definition of the Term “Fiduciary”; Conflict of Interest Rule-Retirement Investment Advice; Best Interest Contract Exemption (Prohibited Transaction Exemption …
    ERISAProposed Rules (FR)Proposed Mar 2, 2017
    …Rs contained in the amendments to Part V impose no additional burden on respondents. Amended PTE 86-128: The information collections in Amended PTE 86-128 are approved under OMB Control Number 1210-0059. As amended, Section III of the exemption requires Financial Institutions to make certain disclosures to plan fiducia…
  5. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ds of thousands of dollars in DISC commissions each year from a well-established business, and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount. -28IV. Section 6662(a) Penalty Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
  6. 81 FR 40548 — Deferred Compensation Plans of State and Local Governments and Tax-Exempt Entities
    IRCProposed Rules (FR)Proposed Jun 22, 2016
    …d the rate of return being credited on the account (from October 1, 2017 until October 1, 2022) is $128,336. The participant has a severance from employment on October 16, 2020, and is paid $135,379 on that date. (ii) Conclusion. The amount included in income on the applicable date (October 1, 2017) is $128,336. Pursua…
  7. T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred…
    IRCTreasury DecisionsFeb 6, 2006related by meaning
    …sted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for February 2006. T.D. 9238 T.D. 9238 Temporary and proposed regulations under section 7874 of the Code provide for determination of whether a foreign cor…
  8. REG-117270-25 — Notice of Proposed Rulemaking
    IRCProposed Rules (FR)Proposed Mar 23, 2026
    …criteria under section 6434 for who can make the election for a pilot program contribution. Section 128 employer contributions paid to a Trump account of an employee or a dependent of an employee are not includible in the employee’s income. Such contributions are limited to $2,500, subject to cost-of-living adjustments…
  9. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    IRCCourt RulingsJul 26, 1989related by meaning
    June 19, 1986, the Court of Appeals affirmed our decision sub nom. Dillon v. United States, 792 F.2d 849 (9th Cir. 1986). The parties also stipulated: Petitioners accept the determination of tax contained in the deficiency notice as mathematically correct, except they contend that the tax should be computed by applying…
  10. I.R.C. § 6652(c)(2)(C) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(2)(C) (C) Split-interest trusts In the case of a trust which is required to file a return under section 6034(a), subparagraphs (A) and (B) of this paragraph shall not apply and paragraph (1) shall apply in the same manner as if such return were required under section 6033, except that— In addition to any penalty im…
  11. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    States, 434 U.S. at 533; Bingler v. Johnson, 394 U.S. 741, 749-750 (1969), (quoting Commissioner v. South Texas Lumber Co., 333 U.S. 496, 501 (1948)). If a regulation is found to be in conflict with the statute, the regulation is invalid to that extent. Citizen's National Bank of Waco v. United States, 417 F.2d 675, 67…
  12. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    ion 6662(a) and (b) (2). Generally, section 6662(a) and (b) (1) authorizes the Commissioner to impose a 20-percent penalty on the portion of an - 72 - underpayment of income tax attributable to negligence or disregard of rules or regulations. The term "negligence" includes any failure to make.a reasonable attempt to co…
  13. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962. To…
  14. T.C. Memo. 2014-27 — Boyd J. Black & Janice C. Black v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    includible in income under section 61(a)(12) and subject to tax. However, this issue is moot because petitioners' debts were not discharged but rather extinguished, and thus petitioners' income was not from discharge of indebtedness. III. Accuracy-Related Penalty Section 6662(a) imposes an accuracy-related penalty equa…
  15. T.C. Memo. 2016-110 — Kenneth L. Mallory & Larita K. Mallory v. Commissioner
    IRCCourt RulingsJun 6, 2016related by meaning
    igher than not frivolous. R sec. 1.6662-4(e)(2)(i). A return position that is merely arguable does not satisfy the reasonable basis standard. Id. -16- [*16] sec. 1.6662-3(b)(3). A position generally has a reasonable basis if the position is reasonably based on one or more authorities listed in section 1.66624(d)(3)(iii…