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41. 88 FR 60018 — Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements
    IRCProposed Rules (FR)Proposed Aug 30, 2023related by meaning
    d any subcontractors consistent with the labor hour requirement of section 45(b)(8)(A) and the participation requirement of section 45(b)(8)(C); and ( 6) Whether the taxpayer made no attempt to comply with the Apprenticeship Requirements. (D) Rebuttable presumption of no intentional disregard. If a taxpayer makes the p…
42. I.R.C. § 6662(d)(2)(B)(ii)(I) — Imposition of accuracy-related penalty on underpayments
    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)(…
43. 131 T.C. No. 15 — Larry G. & Maria A. Walton Mitchell v. Commissioner
    IRCCourt RulingsDec 15, 2008
    …the same taxable years (1993 and 1994) is not binding with respect to her proceeding under sections 6320 and 6330. Although this Court’s decision for petitioner’s 1993 and 1994 tax years is not precedential for any other case, it is final and determinative as it relates to petitioner’s liability for those years. It app…
44. 89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAFinal Rules (FR)Jan 24, 2024related by meaning
    nt must promptly notify the Department in writing if it learns that a material fact or representation has been omitted from the exemption application. (b) If, at any time during the pendency of an exemption application, the applicant or any other party in interest who would participate in the exemption transaction beco…
45. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005
    …spouses filing joint returns was available under sec. 6013(e). collection proceeding under sections 6320 and 6330. 5 In the instant case, petitioner raised his claim for relief from joint and several liability as an affirmative defense in a petition for redetermination of a deficiency filed pursuant to section 6213(a).…
46. 89 FR 102735 — Disclosure of Records
    IRCFinal Rules (FR)Dec 18, 2024related by meaning
    tutional by a court of competent jurisdiction, all remaining provisions shall continue in effect. IV. Procedural Requirements A. Executive Order 12866 This rule is not a significant regulatory action as defined in E.O. 12866, dated September 30, 1993, as amended, and is not a major rule under 5 U.S.C. 804. B. Administr…
47. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004
    … issued Mr. and Mrs. Molina a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. Appeals Officer Becker determined that Mr. and Mrs. Molina properly reported the $19,620 distribution on - 5 - their 2000 return and that they had sufficient income and assets
48. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ess doctrine, courts may invalidate laws if "'men of common intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor - - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945 F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra addresses tran…
49. 29 C.F.R. § 2570.6 — Consent order or settlement.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, the following shall apply in lieu of § 18.9 of this title.
50. Circular 230 § 10.50(c) — Sanctions.
    Joint BoardRegulationsOct 11, 2017related by meaning
    (c) (c) Authority to impose monetary penalty (c)(1) (1) In general. (c)(1)(i) (i) The Secretary of the Treasury, or delegate, after notice and an opportunity for a proceeding, may impose a monetary penalty on any practitioner who engages in conduct subject to sanction under paragraph (a) of this section. (c)(1)(ii) (ii…
51. 29 C.F.R. § 2520.101-2(h) — Filing by multiple employer welfare arrangements and certain other related entities.
    ERISARegulationsOct 1, 2020related by meaning
    (h) (h) Penalties (h)(1) (1) Civil penalties and procedures. For information on civil penalties under section 502(c)(5) of ERISA for persons who fail to file the information required under this section, see § 2560.502c-5 of this chapter. For information relating to administrative hearings and appeals in connection with…
52. 29 C.F.R. § 2570.34(f)(11)(i)(E) — Information to be included in every exemption application.
    ERISARegulationsApr 8, 2024related by meaning
    (f)(11)(i)(E) (E) Any felony or conspiracy involving the larceny, theft, robbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds or securities; or (f)(11)(ii) (ii) A statement describing the applicable investigation, examination, litigation,…
53. 29 C.F.R. § 2560.502i-1(e) — Civil penalties under section 502(i).
    ERISARegulationsJan 1, 2017related by meaning
    (e) (e) Computation of the section 502(i) penalty. (e)(1) (1) In general, the civil penalty under section 502(i) is determined by applying the applicable percentage (five percent or one hundred percent) to the aggregate amount involved in the transaction. However, a continuing prohibited transaction, such as a lease or…
54. T.C. Summary Opinion 2003-120 — Laura Ann Flood v. Commissioner
    IRCCourt RulingsAug 27, 2003
    …dent issued a Letter 3193-c, Notice of Determination Concerning Collection Action(s) Under Sections 6320 And/Or 6330, in which respondent determined that the two Notices of Federal Tax Lien filed against petitioner would not be released or withdrawn. This Court must decide: (1) Whether petitioner is entitled to amend h…
55. I.R.C. § 3405(e)(12) — Special rules for pensions, annuities, and certain other deferred income
    IRCCode / StatuteJan 12, 2018related by meaning
    (e)(12) (12) Failure to provide correct TIN If— no election under subsection (a)(2) or (b)(2) shall be treated as in effect and subsection (a)(4) shall not apply to such payee. (e)(12)(A) (A) a payee fails to furnish his TIN to the payor in the manner required by the Secretary, or (e)(12)(B) (B) the Secretary notifies …
56. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
    nformation available for law enforcement and other users to detect potential money laundering, terrorist financing, and other tax and financial fraud. These proposed regulations would require filers who are required to file at least the applicable number of returns identified in paragraphs (b)(1) and (b)(2) of proposed…
57. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015
    …D OPINION MARVEL, Judge: In a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330¹ (notice of determination), respondent ¹Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) as amended and in effect at all relevant times, and all Rule references …
58. 29 C.F.R. § 2560.502c-2(a) — Civil penalties under section 502(c)(2).
    ERISARegulationsJan 1, 2017related by meaning
    (a) (a) In general. (a)(1) (1) Pursuant to the authority granted the Secretary under section 502(c)(2) of the Employee Retirement Income Security Act of 1974, as amended (the Act), the administrator (within the meaning of section 3(16)(A)) of an employee benefit plan (within the meaning of section 3(3) and § 2510.3-1, …
59. 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
    01.6404-4. * * * * * § 301.6404-4 Suspension of interest and certain penalties when the Internal Revenue Service does not timely contact the taxpayer. (a) Suspension. (1) In general. (2) Treatment of amended returns and other documents. (i) Amended returns filed on or after December 21, 2005, that show an increase in t…
60. T.C. Memo. 2012-94 — Child Adult Intervention Services, Inc. v. Commissioner
    IRCCourt RulingsMar 28, 2012
    …espondent issued petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice), sustaining the proposed levy. The notice stated the SO had verified that all legal and procedural requirements had been met for the assessment of the 2005 and 2007 late-filing penalties. The no…