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.
IRCCourt RulingsDec 11, 2003related by meaning
Commissioner to disregard the
deficiency procedures and immediately assess and collect any
unpaid section 6654 addition. Section 6213(a) prohibits the Commissioner from immediately assessing and collecting the
section 6654 addition in a post-notice return situation, however,
because section 6665(b)(2) indisputably make…
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…
IRCCourt RulingsJan 6, 1997related by meaning
etitioners are liable for an
accuracy-related penalty of $4,870 pursuant to section 6662(a)
for 1991. Section 6662 imposes a 20-percent penalty on any portion of any underpayment that is attributable to any
substantial understatement of income tax. Sec. 6662(a)(2),
- 14 -
(b)(2). Respondent based the determination of t…
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…
IRCCourt RulingsJun 23, 2025related by meaning
one fluent in English knows that the word ‘includes’ cannot be assumed
to mean ‘includes only .’ . . .”) ; Waltne r , 107 T.C.M. (CCH) at 1201 (citing United States v. Lat ham , 754 F.2d 747, 750 (7th Cir. 1985) ) .
In sum, petitioner’s arguments have been rejected by the courts
in hundreds of cases, and we will not di…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
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…
IRCCourt RulingsJun 14, 2012related by meaning
_
requirements under section 6020(b) Wheeler v. Commissioner, 127 T.C. 200
208-209 (2006), aff'd, 521 F.3d 1289 (10th Cir. 2008). A return made by the Secretary under section 6020(b) is'treated as the return filed by the taxpayer for
purposes of section 6651(a)(2). Sec. 6651(g)(2). Respondent'satisfied his burden
by in…
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 88494 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges IRCFinal Rules (FR)Dec 21, 2023
…the No Surprises Act.
U.S.C.-Brookings Schaeffer on Health Policy.
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/03/16/recommendations-for-implementing-the-no-surprises-act/.
IRCPrivate Letter RulingsApr 30, 2010
… April 01, 2010 2:59:47 PM
To: ------------------
Cc:
Subject: RE: ERISA question
The pr ovision 29 USC 1104(b) that you are referring to is section 404(b) of ERISA, that provides that
no fiduciary may maintain the indicia of ownership of any assets of a plan outside the jurisdiction of the
District Courts of the U.S.,…
78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-… IRCFinal Rules (FR)Nov 13, 2013
…ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
List of Subjects
26 CFR Part 54
Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590
Continuation c…
IRCCourt RulingsJul 21, 2014related by meaning
account transcript showing that he did not file a 2009 return.
The only evidence that petitioner produced was his own uncorroborated testimony,
- 8 - [*8] which, for the reasons previously stated, we do not find credible. We will
therefore sustain the imposition of the section 6651(a)(1) addition to tax.
B. Section 66…
PBGCPBGC Opinion LettersSep 30, 1994
…( 4)( B)>
421 9 N otice & Co llection o f W ithdraw al Liab ility
422 1 Reso lution of Disputes
>29 USC 1461 n ote >
OP INI ON :
I
wri te i n res ponse t o your reque st for the opini on
of the Pension Benefit Guaranty Corporation ("PBG C").
Your
fir st r equest c oncerns a par ticu lar
applicat ion of t he princ iples…
IRCCourt RulingsDec 2, 2010related by meaning
0 T.C.
163 (2003)]. * * *
Wheeler v. Commissioner, 127 T.C. 200, 210 (2006), affd. 521
F.3d 1289 (10th Cir. 2008). The section 6651(a) (2) addition to tax is not imposed if the taxpayer proves that the failure to pay
is due to reasonable cause and not willful neglect.
Under section 6651(g) (2), a return prepared by the…
IRCCourt RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…
75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient… IRCFinal Rules (FR)Jul 23, 2010
…ing Department of Labor claims procedure regulation. That is, the Department of Labor interprets 29 USC 1133 and the DOL claims procedure regulation as already requiring that plans provide claimants with new or additional evidence or rationales upon request and an opportunity to respond in certain circumstances.
See
Br…
75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections IRCFinal Rules (FR)Jun 28, 2010
… read as follows:
Authority:
2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
5. Add § 147.108 to read as follows:
§ 147.108
Prohibition of preexisting condition exclusions.
(a)
No preexisting condition exclusions
—(1)
In general.
A …
IRCCourt RulingsApr 2, 2020related by meaning
period starts with the due
date of the return. Sec. 6501(b)(1).
- 13 -
[*13] taxpayer signing the Form 4549 waives the section 6213(a) prohibition on the IRS's assessing a tax deficiency without the mailing of a notice of deficiency.
S_e_e sec. 6213(d) (stating that taxpayers may waive restrictions on assessment
provi…