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41. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011related by meaning
    use these regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Code, the notice of proposed rulemaking preceding these regulations was submitted to the Chief Counsel for Advocacy of the Small Busin…
42. T.C. Memo. 2008-249 — David A. Hughes v. Commissioner
    IRCCourt RulingsNov 3, 2008
    …required to maintain record s sufficient to establish the amount of any deduction . claimed . Sec . 6001 ; sec . 1 .6001-1(a), Income Tax Regs . Even when .a taxpayer is unable to substantiate the amount o f a deduction, the Court may still allow the deduction, or a portion thereof, if there is an evidentiary basis for…
43. 75 FR 42662 — Debt Collection
    PBGCProposed Rules (FR)Proposed Jul 22, 2010related by meaning
    debtor's employing agency or to the Financial Management Service to implement salary offset, unless the employee files a timely request for a hearing; (v) That a final decision on the hearing, if requested, will be issued at the earliest practicable date, but not later than 60 days after the filing of the request for a…
44. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    …ioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Section 6001 requires taxpayers to maintain records sufficient to establish the amount of each deduction. See also sec. 1.6001-1(a), Income Tax Regs. Section 162(a) allows a deduction for ordinary and necessary expenses that a t…
45. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation 52.  5 U.S.C. 601 et seq. Back to Citation 53.  5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551. Back to Citation 54.  Public Law 104-4, 109 Stat. 48 (Ma…
46. T.C. Memo. 2009-100 — Peter I. & Daria A. Basalyk v. Commissioner
    IRCCourt RulingsMay 14, 2009
    …come, deductions or other matters required to be shown on any : information or tax return . Sec . . 6001 ; sec . 1 .6001-1(a), Income Tax Regs . Schedules E Depreciation Expense Deduction s Section 167(a) allows a'depreciation deduction for the exhaustion, wear and tear .of property used in a trade or business or prope…
47. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002
    …yers are required to maintain records sufficient to substantiate their claimed deductions. See sec. 6001; sec. 1.6001-1(a), Income Tax Regs. Generally, a taxpayer is entitled to a deduction for qualified retirement contributions. Sec. 219(a); sec. 1.2191(a), Income Tax Regs. As relevant herein, section 219(e) defines a…
48. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …ome during the subject years and failed to file Federal income tax returns for those years. Section 6001 requires that taxpayers keep books and records which are sufficient to establish (among other things) their gross income, deductions, and credits and which allow the Commissioner to verify their correct tax liabilit…
49. T.C. Summary Opinion 2004-1 — Lawrence K. Mudd v. Commissioner
    IRCCourt RulingsJan 8, 2004
    …t to establish the amounts of the items required to be shown on his Federal income tax return. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs. In the event that a taxpayer establishes that a deductible expense has been paid but is unable to substantiate the precise amount, we generally may estimate the amount of the…
50. 85 FR 31710 — Guidance Clarifying Premium Tax Credit Unaffected by Suspension of Personal Exemption Deduction
    IRCProposed Rules (FR)Proposed May 27, 2020related by meaning
    e made electronically. If a public hearing is scheduled, notice of the date, time, and place for the hearing will be published in the Federal Register . Announcement 2020-4, 2020-17 IRB 1, provides that until further notice, public hearings conducted by the IRS will be held telephonically. Any telephonic hearing will b…
51. 78 FR 20039 — Reportable Events and Certain Other Notification Requirements
    PBGCProposed Rules (FR)Proposed Apr 3, 2013related by meaning
    llion. (1) Form 200 must be filed with PBGC no later than 10 days after the due date for any required payment for which payment was not made when due. (2) If a contributing sponsor or the ultimate parent completes and submits Form 200 in accordance with this section, PBGC will consider the notification requirement in s…
52. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019
    … must maintain records that sufficiently substantiate the amounts of their claimed deductions. Sec. 6001; see Hradesky v. Commissioner, 65 T.C. 87, 89-90 (1975), 7Petitioners provided only the French language documents, which are not admissible. See supra pp. 6-7. -12aff'd per curiam, 540 F.2d 821 (5th Cir. 1976); sec.…
53. T.C. Memo. 2011-99 — James D. & Bobbie Rogers v. Commissioner
    IRCCourt RulingsAug 1, 2011
    …maintain records sufficient to enable the Commissioner to determine his correct tax liability. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs. Although we found petitioner's testimony to be generally credible, petitioner's testimony by itself was insufficient to substantiate an
54. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014
    …must also maintain adequate records to substantiate the amounts of any credits and deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs. II. Rollover Contributions Section 408(d) governs distributions from qualified retirement plans. Generally, section 408(d)(1) provides that any amount distributed from an individu…
55. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    utes] × $63.45 = $793. Back to Citation 65.  5 U.S.C. 601 et seq. Back to Citation 66.  5 U.S.C. 601(2), 603(a); see5 U.S.C. 551. Back to Citation 67.  Public Law 104-4, 109 Stat. 48 (Mar. 22, 1995). Back to Citation 68.  Reorganization Plan No. 4 of 1978 (5 U.S.C. App. 1 (2018)) generally transferred the authority of …
56. T.C. Memo. 2013-42 — Roger Phillips v. Commissioner
    IRCCourt RulingsFeb 7, 2013
    …ablish the taxpayer's correct tax liability. Higbee v. Commissioner, 116 T.C. at 440; see also sec. 6001. The taxpayer must produce such records upon the Secretary's request. Sec. 7602(a); see also sec. 1.6001-1(e), Income Tax Regs. Adequate substantiation must establish the amount and purpose of a claimed deduction. H…
57. I.R.C. § 6057(h) — Annual registration, etc.
    IRCCode / StatuteJan 6, 2025related by meaning
    (h) (h) Cross references For provisions relating to penalties for failure to register or furnish statements required by this section, see section 6652(d) and section 6690. For coordination between Department of the Treasury and the Department of Labor with regard to administration of this section, see section 3004 of t…
58. T.C. Memo. 2009-133 — Paul Rudnick v. Commissioner
    IRCCourt RulingsJun 9, 2009
    …r must satisfy strict substantiation requirements before a deduction is allowable . Se e also sec . 6001 ; sec . 1 .6001-1(a), (e), Income Tax Regs . ii -1 7 Respondent does not dispute that etitioner had a business or that he was involved in that business with continuity and regularity and for profit . Respondent cont…
59. T.C. Summary Opinion 2009-77 — Gary W. & Regina G. Steele v. Commissioner
    IRCCourt RulingsMay 14, 2009
    … S . 79, 84 (1992 ) ; New Colonial Ice Co . v . =` Helvering , 292 U . S .435 , 440 (1934 ) Section 6001 requires taxpayers to-maintain records, statements , and returns and to comply with such rules and regulations as the Secretary prescribes . Individual taxpayers .are to keep permanent books and r .ecords ., suffici…
60. Circular 230 § 10.82(b)(4)(ii) — Expedited suspension.
    Joint BoardRegulationsDec 30, 2016related by meaning
    (b)(4)(ii) (ii) Advancing frivolous or groundless arguments; or (b)(4)(iii) (iii) Failing to pursue available administrative remedies. (b)(5) (5) Has demonstrated a pattern of willful disreputable conduct by— (b)(5)(i) (i) Failing to make an annual Federal tax return, in violation of the Federal tax laws, during 4 of t…