IRCCourt RulingsMay 20, 2009
…ginal terms ; or (2) a new loan for a smaller amount .
Petitioner chose the refinancing loan of $12,346 .95 .3 I f
.petitioner had borrowed on the "original terms", as he had in
2004, he would have had to repay the $12,346 .95 in 77 payments .
Instead, the replacement loan reset the number of remaining
payments to the …
U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner IRCCourt RulingsDec 13, 2018related by meaning
ners are liable under section 6662(a) and
(b)(2) for an accuracy-related penalty on an underpayment due to a substantial
understatement of income tax. Section 6662(a) imposes a 20% accuracy-related penalty on any portion of
an underpayment of tax required to be shown on a return if, as provided by section
6662(b)(2), t…
49 T.C. 174 — Armanco Productions, Inc. v. Commissioner IRCCourt RulingsDec 8, 1967
…, if the trust is qualified, the maximum deduction possible under section 404(a)(3)(A) would be $10,346.69.
On the state of the record before us, we, are of the opinion that petitioner has not met its burden of proving that it is entitled to the claimed deduction of $53,491.08 for the taxable period ended April 30, 196…
IRCCourt RulingsSep 10, 2015related by meaning
m nt of tax attributable to: (1) negligence or disregard of rules and
regulations; or (2) a substantial understatement of income tax. Sec. 6662(a) and (b)(1) and (2). Negligence is defined to include any failure to make a reasonable
attempt to comply with the Internal Revenue Code. Sec. 6662(c). The statute
defines dis…
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.
Rev. Proc. 2020-46 — This revenue procedure modifies and updates Rev. Proc. 2016-47, 2016-37 I.R.B. 346, which provides a list of permissible reasons for a taxpayer to self-certify… IRCRevenue ProceduresNov 2, 2020
…6
SECTION 1. PURPOSE
This revenue procedure modifies and updates Rev. Proc. 2016-47, 2016-37 I.R.B. 346. Section 3.02(2) of Rev. Proc. 2016-47 provides a list of permissible reasons for self-certification of eligibility for a waiver of the 60-day rollover requirement. In response to requests from stakeholders, this rev…
IRCCourt RulingsMay 19, 2011related by meaning
Sanction Awarded by the Court
We now consider sua sponte whether to impose a penalty
against petitioner pursuant to section 6673(a) (1). That section allows the Court to impose upon a taxpayer a penalty of up to
$25,000 whenever it appears that the taxpayer instituted or
maintained a proceeding primarily for delay or …
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
…aning of § 306(b)(4).
(25)
Sections 331 and 332.—See section 4.01(23), above.
(26) Sections 331 and 346(a).—Gain or Loss to Shareholders in Corporate Liquidations.—The tax effect of the liquidation of a corporation by a series of distributions, when the distributions in liquidation are to be made over a period in exces…
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
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
…aning of § 306(b)(4).
(25)
Sections 331 and 332.—See section 4.01(23), above.
(26) Sections 331 and 346(a).—Gain or Loss to Shareholders in Corporate Liquidations.—The tax effect of the liquidation of a corporation by a series of distributions, when the distributions in liquidation are to be made over a period in exces…
PBGCRegulationsJan 1, 2017
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
PBGCRegulationsJan 1, 2017
…t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
PBGCRegulationsJan 22, 2018
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
… a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information.
3
Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here:
https://www.bls.gov/news.release/pdf/jolts.pd…
IRCCourt RulingsJun 6, 2016related by meaning
racy-related penalty under section
6662(a) and (b)(2) for an underpayment due to a substantial understatement
of income tax for the 2011 taxable year. Section 6662(a) imposes a 20% "accuracy-related penalty" on an
underpayment of tax attributable to any of the causes listed in section 6662(b).
These causes include "[a]…
T.C. Memo. 2017-77 — Estate of Hung-Liang Lynn Lin, Deceased, Jeffrey S. Lin, Administrator v. Commissioner IRCCourt RulingsMay 8, 2017related by meaning
penalty on an underpayment due to a substantial
understatement of income tax.
Section 6662(a) imposes a 20% accuracy-related penalty on any portion of an underpayment of tax required to be shown on a return if, as provided by section
6662(b)(2), the underpayment is attributable to any substantial understatement of
inco…
IRCCourt RulingsJan 19, 2010related by meaning
JOHN C . . A MBRUST, Petitioner v .
COMMISSTONEROF INTERNAL 'REVENUE, Responden t
.° Filed .' January` "19, 2010 .
GOLDBERG , Specia l Trial" Judge : ,' This case w as heard-pursuant
to the provision ` s of secti n6 7463 of' .the Internal Revenue Code i n
effect at the time the {pet'tion was filed . Pursuant ' to '-sec…
IRCCourt RulingsFeb 6, 1992related by meaning
n is subject to section 404. It is difficult, if not impossible, to discuss deferring receipt of compensation without focusing on the time of payment. We also reject petitioner's contention that the case at hand is similar to that in Minahan v. Commissioner, 88 T.C. 492 (1987). We held, in that case, that the Secretary…
IRCCourt RulingsJul 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
IRCCourt RulingsSep 1, 2016related by meaning
Penalty
Respondent determined an accuracy-related penalty of $5,281 for a
substantial understatement of Federal income tax. Section 6662(a) and (b)(2) authorizes a 20% penalty on the portion of an underpayment of income tax
attributable to a substantial understatement of income tax. Under section 7491(c),
the Commissio…