ERISARegulationsJan 1, 2017
…f return; or
(d)(3)(ii)(B) (B) Interest at a rate equal to the underpayment rate defined in section 6621(a)(2) of the Internal Revenue Code from the date on which such contributions were paid to, or withheld by, the employer until such money is fully restored to the plan.
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
ERISARegulationsAug 12, 2025
… paragraph (i)(5)(ii) of this section at the “underpayment rate” as set forth in 26 U.S.C. sections 6621 and 6622. Such interest must be paid within the earlier of 60 days of detection by the insurer or sixty days following receipt of written notice of non-compliance from the plan.
IRCCourt RulingsJan 12, 1998related by meaning
tely $1,026,855 in U. S.
currency deposited into various bank accounts during the period
January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts
alleging violations of customs reporting requirements.
On January 9, 1992, petitioner entered into a plea a…
IRCCourt RulingsFeb 28, 2024related by meaning
d a refund may be ordered by
such court of any amount col lected within the period during
which the Secretary is prohibited from collecting by levy or through a proceeding in court under the provisions of [section 6213(a)] .
4. Coordination of Section 6501 and 6213 Rules
Section 6503, titled “ Suspension of running of …
81 FR 47534 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Jul 21, 2016
…,” is the amortization base eligible for amortization using interest rates applicable under section 6621(b) of the Code for years beginning after 2007? ☐ Yes ☐ No
8(e) [Current]
If box 5h is checked or Line 8c is “Yes,” enter the difference between the minimum required contribution for the year and the minimum that wou…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
IRCCourt RulingsJul 31, 2000
…x under section 6651(a) for failure to file
timely its 1992 Federal income tax return and a section 6621
increased rate of interest on its 1991 deficiency as to interest
accruing after July 20, 1995.
Each petitioner petitioned the Court to redetermine
respondent’s determinations. Respondent’s notices of deficiency
- 5 …
IRCCourt RulingsJul 10, 2017
…w look generally at reasonable cause. The undersigned
[petitioners] spent 20 years fighting section 6621 penalties and
valuation penalties associated with the infamous FoodSource cases.
* * * All those taxpayers wanted to pay the taxes and the interest; it
was the penalties that made the bills onerous. * * * These are …
IRCCourt RulingsAug 1, 2005related by meaning
his annuity policies. As
stated earlier, section 72(e)(5) applies to the surrender of an
annuity contract. See sec. 72(e)(5)(E). Absent exceptions not applicable in the instant case, the law is well settled that a
distribution upon the complete surrender of an annuity contract
is includable in gross income to the exten…
IRCCourt RulingsAug 24, 2000
…percent of the
interest due on the deficiency and that the increased interest
provisions of section 6621(c) applied. Assuming that the
adjustments pertaining to SLA are properly before this Court in
this proceeding, petitioners and respondent have reached an
agreement as to the deficiency and additions to tax. The issu…
IRCCourt RulingsJun 9, 2005
…e added to the
tax an amount determined by applying the underpayment rate
established under section 6621 to the amount of the underpayment
- 12 -
for the period of the underpayment. Unless the taxpayer
demonstrates that one of the statutory exceptions applies,
imposition of the section 6654(a) addition to tax is mandat…
IRCCourt RulingsSep 25, 1996
…e to the
Tax Court Rules of Practice and Procedure.
and 6661, and additional interest under section 6621(c).
2
By
agreement of the parties, resolution of petitioners' liabilities
for the additions to tax and additional interest has been
reserved for other proceedings.
In five other cases, respondent determined administ…
IRCCourt RulingsDec 8, 1987
…der issues relating to interest, it has expressly granted us jurisdiction to do so. See, e.g., sec. 6621(c)(4), I.R.C. 1986 (relating to jurisdiction of this Court to determine increased rate of interest on substantial underpayments of tax attributable to tax-motivated transactions).
IRCPrivate Letter RulingsMay 22, 2015
… is determined for any prior taxable year by applying the
applicable rate of interest under section 6621 plus one percentage point to determine
the underpayment interest under section 6601 that would be due for the underpayment
as of the last day of the taxable year of the section 409A failure. Prop. §1.409A - 4(d)(4)
…
Joint BoardRegulationsDec 30, 2016related by meaning
(a)(5) (5) Solicitation of employment as prohibited under § 10.30, the use of false or misleading representations with intent to deceive a client or prospective client in order to procure employment, or intimating that the practitioner is able improperly to obtain special consideration or action from the Internal Reven…
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)(…
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…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
IRCCourt RulingsDec 30, 2013related by meaning
the amount of tax imposed that is shown on the return, reduced by any
rebate. Sec. 6662(d)(2)(A). The amount of the understatement is reduced by that portion of the understatement that is attributable to (1) the tax treatment of any
item if there is or was substantial authority for such treatment, or (2) any item if
t…