IRCCourt RulingsMar 19, 2025
…021 . W e previously ruled that we do not have jurisdiction over petitioner’s 2017 tax year . See § 6213(a).
P etitioner has not produced any N otice of D eficiency or other IRS
determination with respect to the 2017 tax year that would give us
jurisdiction to consider his refund claim . Our jurisdiction over refund
cl…
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…
IRCCourt RulingsJul 11, 2024
…ioned the Court with
respect to the 2015 NOD , and the case was assigned D ocket No. 1553518. See § 6213(a). On October 21 , 2019, petitioners timely petitioned
the Court with respect to the 2016 NOD , and that case was assigned
D ocket No. 18978- 19. See §§ 6213(a), 7503. In each P etition , petitioners
identified Ida…
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
(c)(3)(i), and (f) to read as follows:
§ 1.6050I-2
Returns relating to cash in excess of $10,000 received as bail by court clerks.
* * * * *
(c) * * * (1) * * * (i) In general. The information return required by this section must be filed in accordance with the Form 8300 instructions and related publications by the 15t…
IRCCourt RulingsAug 30, 2006
…nt on the issuance of a valid notice of deficiency and the
timely filing of a petition. Secs. 6212, 6213; Rule 13(a), (c).
To be timely, a petition must generally be filed within 90 days
of the date the notice of deficiency is issued by the
Commissioner. If a petition is not filed within the 90-day
period, this Court d…
IRCCourt RulingsAug 8, 2000
f sections 6212(a) and 6213(a).
- 5 -
Because this Court is a court of limited jurisdiction,
petitioner’s fraud argument is misplaced. The Court lacks jurisdiction to review or set aside the order of discharge
entered by the bankruptcy court. Therefore, petitioner’s
contention that the bankruptcy discharge is void beca…
77 FR 37352 — Reporting and Notice Requirements for Deferred Vested Benefits Under Section 6057 IRCProposed Rules (FR)Proposed Jun 21, 2012related by meaning
ents or to request a public hearing, Oluwafunmilayo Taylor, (202) 622-7180 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act The collection of information contained in this notice of proposed rulemaking has been approved by the Office of Management and Budget for review in accordance with the …
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…
IRCCourt RulingsMay 6, 2014
…l rule that assets must be liquidated to qualify for an installment agreement. We disagree.
Section 6213(a) bars the Commissioner from assessing a tax liability until
our decision becomes final, and section 7481 makes our decisions final when
opportunities for appeal have been exhausted. Section 7485(a)(1), however,
su…
IRCCode / StatuteJan 5, 2023related by meaning
(d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and
(d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer.
(d)(2)(C) (C) Reduction not to apply to tax shelters
(d)(…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026related by meaning
The Tax Court denied the IRS’s motion to dismiss the case for lack of jurisdiction. In a unanimous opinion, the Tax Court held that section 7508A(d) (as amended in 2019) unambiguously provided for an automatic and mandatory postponement period that incorporated all of the acts referenced by section 7508A(a), from the e…
78 FR 13797 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements ERISAFinal Rules (FR)Mar 1, 2013related by meaning
g rise to the order, and, where applicable, a copy of any warrant or other authorization by a court.
§ 2560.521-2
Disclosure of order and proceedings. (a) Notwithstanding § 2560.521-1(e)(8), the Secretary shall make available to the public final cease and desist and summary seizure orders or modifications and terminati…
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
or lack of jurisdiction.
Appropriate orders will be issued.
Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
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…
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.
88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCFinal Rules (FR)Feb 23, 2023related by meaning
ents relating to a single transaction (or two or more related transactions), see paragraph (b) of this section.
* * * * *
(3) * * *
(i)
Where to file. A person making a return of information under this section must file Form 8300 in accordance with the form instructions and related publications.
* * * * *
(h)
Applicabi…
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…
ERISARegulationsJan 1, 2017related by meaning
(b)(2)(ii) (ii) Fraudulent conduct includes any false statement regarding any of paragraphs (b)(2)(i)(A) through (b)(2)(i)(E) of this section that is made with knowledge of its falsity or that is made with reckless indifference to the statement's truth or falsity, and the knowing concealment of material information reg…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
… a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information.
3
Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here:
https://www.bls.gov/news.release/pdf/jolts.pd…