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41. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    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…
42. U.S. Tax Court — James Thomas & Susan Jane Colegrove v. Commissioner
    IRCCourt RulingsApr 13, 2010related by meaning
    drawal . In a notice of deficiency, respondent determined, inter alia, that the $52,132 .27 distribution from the IRA is includable in income and that petitioners are liable for the 10-percent additional tax on the early distribution pursuant to section 72(t) . Discussion In general, the Commissioner's determination as…
43. 76 FR 76222 — Filings Required of Multiple Employer Welfare Arrangements and Certain Other Related Entities
    ERISAProposed Rules (FR)Proposed Dec 6, 2011related by meaning
    dds a cross-reference to section 521 of ERISA and § 2560.521 regarding the Secretary's authority to issue cease and desist and summary seizure orders. B. Proposed Amendment to Regulations Under ERISA Section 104(a)(1), 29 U.S.C. 1024(a)(1)
44. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    required to disclose in that return all of the assets that it held at the end of 2005 and the respective yearend values of all of those assets. - 7 - Under IRC section 4979[A](e)(2)(C), all the deemed owned shares of all the disqualified persons with respect to the Law Office of John H Eggertsen P. C. Employee Stock O…
45. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    ccuracy-related penalty under section 6662. OPINION I. Preliminary Matters Petitioner argues that respondent bears the burden of proof with respect to his unreported income for both tax years. For the reasons below, we disagree. Generally, the Commissioner's determinations in a notice of deficiency are presumed correct…
46. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023related by meaning
    Mendes v. Commissioner, 121 T.C. 308, 312 – 13 (2003) (holding that arguments not addressed in posttrial brief may be considered abandoned); Leahy v. Commissioner, 87 T.C. 56, 73 – 74 (1986) (finding concession by failure to argue). Thus, having established clerical errors in the SNODs for 2015, 2016, and 2017, respon…
47. T.C. Memo. 2007-306 — David Brian Nolan v. Commissioner
    IRCCourt RulingsOct 9, 2007related by meaning
    ers . In response to our leniency, petitioner once again ignored our Rules and our order . -5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a sanction pursuant to Rule 123(b) . See Stringer v . Commissioner , 84 T .C . 693, 704-705 (1985), affd . withou…
48. Treas. Reg. § 1.501(c)(2)-1(a) — Corporations organized to hold title to property for exempt organizations.
    IRCRegulationsJul 12, 2016
    …collecting income therefrom, it cannot have unrelated business taxable income as defined in section 512 other than income which is treated as unrelated business taxable income solely because of the applicability of section 512(a)(3)(C); or debt financed income which is treated as unrelated business taxable income solel…
49. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    ion 6662(a) and (b) (2). Generally, section 6662(a) and (b) (1) authorizes the Commissioner to impose a 20-percent penalty on the portion of an - 72 - underpayment of income tax attributable to negligence or disregard of rules or regulations. The term "negligence" includes any failure to make.a reasonable attempt to co…
50. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    IRCCourt RulingsAug 27, 2018related by meaning
    0 and $5,379, respectively; and (4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014 of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a) penalties in writing by making an entry in the Correspondence Examination Automation Case Support…
51. 88 FR 76660 — Technical Amendments: Special Financial Assistance Withdrawal Liability Condition; SECURE 2.0 Act; and Other Updates
    PBGCFinal Rules (FR)Nov 7, 2023related by meaning
    REQUIREMENTS 16. The authority citation for part 4043 continues to read as follows: Authority: 29 U.S.C. 1083(k), 1302(b)(3), 1343. § 4043.8 [Amended] 17. Amend § 4043.8 by removing “§ 4901.21(a)(3)” and adding in its place “§ 4901.21(a)”. PART 4211—ALLOCATING UNFUNDED VESTED BENEFITS TO WITHDRAWING EMPLOYERS 18. The a…
52. T.C. Memo. 2024-67 — Fabricio Moran v. Commissioner
    IRCCourt RulingsJun 17, 2024related by meaning
    ioner, T.C. Memo. 2013-67, 105 T.C.M. (CCH) 1433, 1439, aff’d , 845 F.3d 971 (9 th Cir. 2017) . An SFR prepared by the IRS pursuant to section 6020(b) is treated as the “return” filed by the taxpayer for this purpose. See § 6651(g). On September 12, 2022, the IRS prepared an SFR setting forth the adjustments discussed …
53. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    United States Tax Court T.C. Memo. 2024-6 CLAIR R. COUTURIER, JR. , Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent ————— Docket N o. 19714-16. Filed January 17, 2024. ————— Michael Eddison Romero , Alvah Lavar Taylor, Daniel W. Soto , and Jonathan T. Amitrano , for petitioner. Hilary E. March , Laura A. Pr…