Treas. Reg. § 54.6694-4(a) — Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural… IRCRegulationsDec 30, 2016related by meaning
(a) (a) In general. For rules relating to the extension of period of collection when a tax return preparer who prepared a return or claim for refund for tax under chapter 43 of subtitle D of the Internal Revenue Code pays 15 percent of a penalty for understatement of taxpayer's liability, and procedural matters relatin…
88 FR 88494 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges IRCFinal Rules (FR)Dec 21, 2023
…the No Surprises Act.
U.S.C.-Brookings Schaeffer on Health Policy.
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/03/16/recommendations-for-implementing-the-no-surprises-act/.
PBGCPBGC Opinion LettersSep 30, 1994
…( 4)( B)>
421 9 N otice & Co llection o f W ithdraw al Liab ility
422 1 Reso lution of Disputes
>29 USC 1461 n ote >
OP INI ON :
I
wri te i n res ponse t o your reque st for the opini on
of the Pension Benefit Guaranty Corporation ("PBG C").
Your
fir st r equest c oncerns a par ticu lar
applicat ion of t he princ iples…
IRCCourt RulingsJun 14, 2012related by meaning
atement for any taxable year, there shall be added to the tax an amount
equal to 20% of the amount of such understatement." The penalty applies to any deficiency which is attributable to any listed transaction or any reportable
transaction if a significant purpose of the transaction is the avoidance or evasion
- 41 -
o…
77 FR 37352 — Reporting and Notice Requirements for Deferred Vested Benefits Under Section 6057 IRCProposed Rules (FR)Proposed Jun 21, 2012related by meaning
dopted as final regulations, consideration will be given to any comments that are submitted timely to the IRS as prescribed in this preamble under the Addresses
heading. The IRS and Treasury Department request comments on all aspects of the proposed rules. All comments are available at
www.regulations.gov
or upon reque…
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…
75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient… IRCFinal Rules (FR)Jul 23, 2010
…ing Department of Labor claims procedure regulation. That is, the Department of Labor interprets 29 USC 1133 and the DOL claims procedure regulation as already requiring that plans provide claimants with new or additional evidence or rationales upon request and an opportunity to respond in certain circumstances.
See
Br…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018related by meaning
18071, 18082, 26 U.S.C. 36B, and 31 U.S.C. 9701); and Public Law 103-141, 107 Stat. 1488 (42 U.S.C. 2000bb-2000bb-4).
List of Subjects
26 CFR Part 54 Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590
Continuation coverage
Disclosure
Employee benefit plans
Grou…
75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections IRCFinal Rules (FR)Jun 28, 2010
… read as follows:
Authority:
2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
5. Add § 147.108 to read as follows:
§ 147.108
Prohibition of preexisting condition exclusions.
(a)
No preexisting condition exclusions
—(1)
In general.
A …
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
curacy-related penalty on
underpayments .” In relevant part, section 6662(a) and (b) provides:
(a) Imposition of penalty. — If this section applies to any portion of an underpayment of tax required to be
shown on a return, there shall be added to the tax an
amount equal to 20 percent of the portion of the
underpayment …
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…the No Surprises Act.
U.S.C.-Brookings Schaeffer on Health Policy.
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/03/16/recommendations-for-implementing-the-no-surprises-act/.
Back to Citation
340.
See,
for example, the proposed 2027 HHS notice of benefit and payment parameters (9…
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 …
IRCCourt RulingsDec 8, 1987related by meaning
tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
IRCCourt RulingsSep 29, 2022related by meaning
ith section
6751(b) (1). That section provides: “ No penalty under this title shall be
assessed unless the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the
9
The SFRs comprise Form s 4549, 886– A, and 13496. That combination of
documents is sufficient to co…
IRCCourt RulingsApr 19, 2004related by meaning
the payment of such tax. * * *
Section 6334(a) exempts from levy: (1) Wearing apparel and
school books; (2) fuel, provisions, furniture, and personal effects; (3) books and tools of a trade, business, or profession;
(4) unemployment benefits; (5) undelivered mail; (6) certain
annuity and pension payments; (7) workmen’…
IRCCourt RulingsNov 6, 2012related by meaning
oneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). However,
the Commissioner bears the burden of proof with respect to any increase in deficiency. See Rule 142(a)(1). Our conclusion, however, is based on a
preponderance of the evidence, and thus the allocation of the burden of proof is
immaterial. See E…
IRCCourt RulingsFeb 25, 2016related by meaning
4. Respondent has allowed exactly those amounts as deductions for 2004
and 2005. Petitioner has made no attempts to provide the Court with evidence of any other payments for travel and meals and entertainment expenses. With the
heightened substantiation requirements under section 274 and the lack of
additional document…
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 RulingsSep 27, 1990related by meaning
. United States, 872 F.2d 564, 568-570 (3d Cir. 1989).
Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023
…the No Surprises Act.
U.S.C.-Brookings Schaeffer on Health Policy.
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/03/16/recommendations-for-implementing-the-no-surprises-act/.
Back to Citation
262.
See
Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Cert…