Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006
…the selling shareholders includes an installment obligation of the purchasing entity.
(33) Sections 332, 351, 368(a)(1)(A), (B), (C), (E) and (F), and 1036.—Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Definitions Relating to Corporate Reorganizations; and Stock for Stock of …
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…the selling shareholders includes an installment obligation of the purchasing entity.
(31) Sections 332, 351, 368(a)(1)(A), (B), (C), (E) and (F), and 1036.—Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Definitions Relating to Corporate Reorganizations; and Stock for Stock of …
IRCCourt RulingsSep 25, 1996
… agreement. Under the
termination agreement, MIT 82 gave up rights to collect the
difference, some $332,158, from MPC.
The Termination Agreement required MIT 82 to distribute
MPC's note for $1,974,901, executed pursuant to the Termination
Agreement, to its partners. Under the Termination Agreement, the
partners were to…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner IRCCourt RulingsFeb 9, 2004
…0; Columbia Iron & Metal Co. v. Commissioner
,
supra
at 9; Sperapani v. Commissioner
, supra
at 329-332; Cary v.
Commissioner
, supra
at 218; cf. Hewitt v. Commissioner
, 109 T.C.
258, 264 (1997) (holding that the taxpayers were not entitled to
deduct amounts in excess of those allowed by the Commissioner for
stock con…
PBGCFinal Rules (FR)Nov 5, 2010related by meaning
ry action” under Executive Order 12866.
Regulatory Flexibility Act
PBGC certifies under section 605(b) of the Regulatory Flexibility Act (5 U.S.C. 601 et seq.) that the amendments in this final regulation will not have a significant economic impact on a substantial number of small entities. The final rule is limited to…
IRCCourt RulingsOct 10, 2018
…on of that doctrine seems a bit ironic here. See dissenting op. p. 61 (citing SEC v. Chenery
Corp., 332 U.S. 194 (1947)). The Chenery doctrine teaches that an administrative
agency must set forth the grounds on which it relied when making its decision,
with no "post hoc rationalizations" allowed. See Burlington Truck L…
IRCCode / StatuteJan 12, 2018related by meaning
(e)(12) (12) Failure to provide correct TIN If— no election under subsection (a)(2) or (b)(2) shall be treated as in effect and subsection (a)(4) shall not apply to such payee.
(e)(12)(A) (A) a payee fails to furnish his TIN to the payor in the manner required by the Secretary, or
(e)(12)(B) (B) the Secretary notifies …
78 FR 39870 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Jul 2, 2013
…also issued under sec. 102 of Reorganization Plan No. 4 of 1978, 43 FR 47713, 3 CFR, 1978 Comp., p. 332 and E.O. 12108, 44 FR 1065, 3 CFR, 1978 Comp., p. 275, and 29 U.S.C. 1135 note. Sec. 2510.3-102 also issued under sec. 102 of Reorganization Plan No. 4 of 1978, 43 FR 47713, 3 CFR, 1978 Comp., p. 332 and E.O. 12108, …
75 FR 8796 — Civil Penalties Under ERISA Section 502(c)(8) ERISAFinal Rules (FR)Feb 26, 2010related by meaning
ch sets forth additional circumstances in which the Service will automatically approve a request to revoke a section 204 election.
Back to Citation
4. An excise tax under Code section 4971(g)(4) generally applies, in addition to any penalty under ERISA section 502(c)(8), in the case of a failure to adopt a rehabilitat…
77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCFinal Rules (FR)Oct 19, 2012
…has adopted the proposed rule with some modifications as suggested by the commenters. Proposed § 29.332 provides the rule for determining when unused sick leave is creditable for the computation of Federal Benefit Payments. Comments objected to § 29.332(b), which provides that for employees separated for retirement aft…
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…
IRCCourt RulingsMay 6, 2014related by meaning
on 6301 empowers the Commissioner to collect the taxes imposed by
the internal revenue laws. To further that objective, Congress has provided that the Commissioner may effect the collection of taxes by, among other methods, liens
and levies. Section 6321 imposes a lien in favor of the United States on all
property and …
90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Aug 15, 2025related by meaning
RT 4065—ANNUAL REPORT
26. The authority citation for part 4065 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1365.
§ 4065.3
[Amended] 27. Amend § 4065.3 by removing “(Approved by the Office of Management and Budget under control number 1212-0026)”.
PART 4203—EXTENSION OF SPECIAL WITHDRAWAL LIABILITY RU…
Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions IRCNoticesAug 24, 2026
…rtain information addressed in this notice will be subject to the Paperwork Reduction Act (PRA), 44 USC 3507. No collection of information will be required until approved by the Office of Management and Budget (OMB) under the PRA.
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…g NQTL comparative analyses and compliance, has a 3-year average hour burden of approximately 1,003,332 hours with an equivalent cost of approximately $166,471,063 and a total cost burden of approximately $107,447. The final amendments to implement the CAA, 2023 provision that sunsets the MHPAEA opt-out election for sp…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…d section 102 of Reorganization Plan No. 4 of 1978 (43 FR 47713 (Oct. 17, 1978)), 3 CFR, 1978 Comp. 332, effective December 31, 1978 (44 FR 1065 (Jan. 3, 1979)), 3 CFR, 1978 Comp. 332, 5 U.S.C. App. 237, and under Secretary of Labor's Order No. 1-2011, 77 FR 1088 (Jan. 9, 2012).
List of Subjects in 29 CFR Part 2510
Emp…
IRCCourt RulingsDec 30, 2013related by meaning
.
- 26 -
return or in a statement attached to the return and there is a reasonable basis for
the taxpayer's treatment of the item. Sec. 6662(d)(2)(B). The Commissioner bears the initial burden of production with respect to the
taxpayer's liability for the section 6662 penalty. Sec. 7491(c). At trial the
Commissioner mu…
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…