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…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
IRCCourt RulingsJan 17, 2024related by meaning
at 568 – 69. Petitioner has not explained why the result should be different here.
Petitioner assert s that the placement of section 4973 in the Code i s “irrelevant,” citing section 7806(b) for the proposition that “[n]o inference, implication, or presumption of legislative construction shall be . . .
made by reason …
82 FR 47409 — Claims Procedure for Plans Providing Disability Benefits; Extension of Applicability Date ERISAProposed Rules (FR)Proposed Oct 12, 2017
…ty for failing to respond, unless such collection displays a valid OMB control number.
See44 U.S.C. 3512.
OMB approved information collections contained in the Final Rule under OMB Control Number 1210-0053. The Department is not modifying the substance of the Information Collection Requests at this time; therefore, no …
IRCFinal Rules (FR)Jun 24, 2011related by meaning
(f)
Penalties.
See section 6651 for failure to file an estate or trust income tax return or failure to pay the amount shown as tax on the return.
(g) Effective/applicability dates.
This section applies to applications for an automatic extension of time to file an estate or trust income tax return filed on or after Jun…
IRCCourt RulingsMar 22, 2007related by meaning
ddition to tax must be
sustained.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or
groundless or the taxpayer has instituted or pursued the
proceeding primarily for delay. Respondent has n…
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
…y for failing to respond, unless such collection displays a valid OMB control number. See 44 U.S.C. 3512.
OMB has approved information collections contained in the final fiduciary rule and new and amended PTEs. The Department is not modifying the substance of the information collection requests (ICRs) at this time; the…
ERISA § 3002(e) (29 U.S.C. § 1202) — Procedures with respect to continued compliance with Internal Revenue requirements relating to participation, vesting, and funding standards ERISACode / StatuteJan 5, 2015related by meaning
(e) (e) Consultative requirements respecting promulgation of proposed or final regulations The Secretary of the Treasury shall consult with the Pension Benefit Guaranty Corporation with respect to any proposed or final regulation authorized by subpart C of part I of subchapter D of chapter 1 of title 26, or by sections…
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.
82 FR 16902 — Definition of the Term “Fiduciary”; Conflict of Interest Rule-Retirement Investment Advice; Best Interest Contract Exemption (Prohibited Transaction Exemption … ERISAFinal Rules (FR)Apr 7, 2017
…y for failing to respond, unless such collection displays a valid OMB control number. See 44 U.S.C. 3512.
The Department has sent a request to OMB to modify the information collections contained in the Fiduciary Rule and PTEs. The Department will notify the public regarding OMB's response to its request in a separate
F…
IRCCourt RulingsMar 3, 2016related by meaning
, petitioner tried to keep his tax records and IRS paperwork
for 10 years.
In 2001 petitioner ran a small pharmacy in addition to working at a Federal Government hospital. On April 19, 2001, he was charged, along with two other
codefendants, with diversion of pharmaceuticals from the Department of Veterans
Affairs, and…
77 FR 8706 — Summary of Benefits and Coverage and Uniform Glossary-Templates, Instructions, and Related Materials; and Guidance for Compliance IRCFinal Rules (FR)Feb 14, 2012
…f the collection of information does not display a currently valid OMB control number.
See44 U.S.C. 3512.
This document relates to the information collection request (ICR) contained in final regulations titled “Summary of Benefits and Coverage and the Uniform Glossary,” which is published elsewhere in this issue of the…
89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities IRCFinal Rules (FR)Apr 25, 2024related by meaning
)(i), as contained in 26 CFR part 1, revised as of April 1, 2024.
Douglas W. O'Donnell,
Deputy Commissioner.
Approved: April 2, 2024.
Aviva Aron-Dine, Acting Assistant Secretary of the Treasury (Tax Policy).
Footnotes
1.
PLR 200923001 (February 26, 2009).
Back to Citation
2.
See also
STAFF OF THE JOINT COMM. ON TAX'…
IRCCourt RulingsSep 10, 2015related by meaning
n October 13, 2011, petitioner's wife sent a final letter to Settlement
Officer Owyhng informing him that petitioner had received his October 6, 2011, letter, and that petitioner had requested an extension of time on September 26,
-7-
[*7] 2011. The letter also reiterated that petitioner had no access to a computer
and…
I.R.C. § 6701(e) — Penalties for aiding and abetting understatement of tax liability IRCCode / StatuteJan 4, 1995related by meaning
(e) (e) Certain actions not treated as aid or assistance For purposes of subsection (a)(1), a person furnishing typing, reproducing, or other mechanical assistance with respect to a document shall not be treated as having aided or assisted in the preparation of such document by reason of such assistance.
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…
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…
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.
IRCCourt RulingsJan 28, 2014related by meaning
her traditional IRA, a qualified retirement plan for purposes of
section 72(t). S_ee sec. 4974(c)(4). Petitioner wife had not attained age 59½ at the time of the July 31, 2008, distribution. Petitioner wife has not shown that she
qualifies for any of the other exemptions in section 72(t)(2). See Phillips v.
Commission…
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…