IRCCourt RulingsDec 11, 1997
…tive for loans, assignments,
and pledges made after Aug. 13, 1982, TEFRA, sec. 236(c), 96
Stat. 510-511 (TEFRA effective date provisions). In applying the
TEFRA effective date provisions governing sec. 72(p)(1) and (2),
the outstanding balance of any loan which is renegotiated,
extended, renewed, or revised after Aug. …
84 FR 33002 — Organizations Under Common Control; Eighty Percent Control Test for a Brother-Sister Controlled Group; Correcting Amendment IRCFinal Rules (FR)Jul 11, 2019related by meaning
ernal Revenue Service will not challenge the application of either published version of the regulation.
List of Subjects in 26 CFR Part 1
Income taxes Reporting and recordkeeping requirements
Correction of Publication
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:
PART 1—INCOME TA…
ERISARegulationsJan 1, 2017related by meaning
(f) (f) Cross reference. See §§ 2570.1-2570.12 of this chapter for procedural rules relating to section 502(i) penalty proceedings.
IRCCourt RulingsFeb 29, 2012
…F is the only part relevant to our inquiry as it sets forth the
rules for taxation of UBTI.
Section 511 imposes a tax on the UBTI of an organization described in
section 501(c)(3). Section 512 defines UBTI as the gross income derived by an
exempt organization from any unrelated trade or business regularly carried on by…
75 FR 46844 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Aug 4, 2010related by meaning
on 53.6071-1 is amended by revising paragraph (g)(3) to read as follows:
§ 53.6071-1
Time for filing returns.
* * * * *
(g) * * *
(3)
Transition rule. A Form 4720, for a section 4965 tax that was due on or before October 4, 2007, will be deemed to have been filed on the due date if it was filed by October 4, 2007, and …
IRCCourt RulingsDec 11, 2003
…hat Schwarzkopf v. Commissioner
, 246
F.2d 731 (3d Cir. 1957), and Rev. Rul. 2003-23, 2003-8 I.R.B. 511, do not “address circumstances in which the taxpayer’s
- 46 -
original return was filed after a notice of deficiency had been
issued.” Majority op. p. 27. I agree. These authorities,
however, support the proposition …
115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner IRCCourt RulingsNov 9, 2000
… VEBA from tax, section 501(b)
subjects a tax-exempt VEBA to tax to the extent provided in
sections 511 through 515 relating to the tax on UBTI. Section
511(a) imposes a tax for each taxable year on the UBTI of a VEBA,
as defined in section 512.
Section 512(a)(1) provides the following general definition
of UBTI:
(1) G…
IRCCourt RulingsAug 22, 1994
…9 and 419A, enacted as part of the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98 — 369, section 511(a), 98 Stat. 854-860, limit the deductibility of employer contributions made to a welfare benefit fund, including a VEBA, to the fund’s “qualified cost” for its taxable year ending with or within the employer’s taxab…
76 FR 60373 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Sep 29, 2011related by meaning
Document Headings
Document headings vary by document type but may contain
the following:
the agency or agencies that issued and signed a document
the number of the CFR title and the number of each part
the document amends, proposes to amend, or is directly
related to
the agency docket number / agency internal file numb…
PLR 202535003 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsAug 29, 2025
Subchapter F contains Sections 511 through 515, which impose an income
tax on the unrelated business activities of organizations exempt from taxation. In Research Corporation v. Commissioner of Internal Revenue , 138 T.C. 192 (2012),
the Tax Court held that an organization exempt from tax under section 501(a) is treate…
IRCCourt RulingsOct 31, 2007related by meaning
ner's legal
obligations here . See, e .g ., Pessin v . Commissioner , 59 T .C .
473, 489 (1972) ; Rosanova v . Commissioner , T .C . Memo . 1985-306 ; Grant v . Commissioner , T .C . Memo . 1980-242 .
-11IV . Section 6673 Penalt y
We now consider whether petitioner should be held liable for
a penalty under section 6673…
88 FR 40638 — Quality Control Standards for Automated Valuation Models IRCProposed Rules (FR)Proposed Jun 21, 2023
… and 2022, which are the most recent annual data available. The deflator was 71.300 in 1995 and 129.511 in 2022, resulting in an inflation adjustment factor of 1.82 (129.511/71.300 = 1.816 and $100 million × 1.82 = $182 million).
Back to Citation
187.
Public Law 105–277, 112 Stat. 2681 (1998).
Back to Citation
[FR Doc…
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…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
…. HHS seeks comment on this proposal. ( printed page 51753)
26. Liability for Penalties (45 CFR 150.511)
In 45 CFR 150.511, HHS proposes to codify the provision in section 1128A(c)(1) of the SSA that provides that HHS will not commence any action to impose a civil money penalty unless such action is commenced within 6 …
ERISARegulationsJan 1, 2017related by meaning
(d) (d) Reconsideration or waiver of penalty to be assessed. The Department may determine that all or part of the penalty amount in the notice of intent to assess a penalty shall not be assessed on a showing that the administrator complied with the requirements of section 101(j), (k), or (l), or section 514(e)(3) of th…
85 FR 77952 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business IRCFinal Rules (FR)Dec 2, 2020
… basis for its exemption under section 501 (or, in the case of an organization described in section 511(a)(2)(B), to the exercise or performance of any purpose or function described in section 501(c)(3)). For example, a college or university described in section 501(c)(3) or 511(a)(2)(B) cannot use the NAICS 2-digit co…
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…
Joint BoardRegulationsOct 11, 2017related by meaning
(a) (a) Authority to censure, suspend, or disbar. The Secretary of the Treasury, or delegate, after notice and an opportunity for a proceeding, may censure, suspend, or disbar any practitioner from practice before the Internal Revenue Service if the practitioner is shown to be incompetent or disreputable (within the me…
87 FR 50240 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations IRCFinal Rules (FR)Aug 16, 2022related by meaning
small business. No comments were received from the Chief Counsel for the Office of Advocacy of the Small Business Administration.
Drafting Information The principal author of these regulations is Seth Groman of the Office of Associate Chief Counsel (Tax Exempt and Government Entities), though other persons in the Treas…
IRCCourt RulingsJan 17, 2024related by meaning
ies.
Subchapter C, consisting solely of section 6751, sets forth “Procedural
Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides
evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…