IRCCourt RulingsApr 2, 2024
…t as provided in sections 6015(e), 6212(a) and (c),
6213(a), 6232(c), 6330(e)(1), 6331(i), 6672(c), 6694(c),
7426(a) and (b)(1), 7429(b), and 7436, no suit for the
purpose of restraining the assessment or collection of any
tax shall be maintained in a ny court by any person,
whether or not such person is the person aga…
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
IRCCourt RulingsMar 12, 2015related by meaning
as
either unable to pay the tax or would suffer an undue hardship if he or she paid on
the due date. See sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Respondent concedes that he has not met his burden of production on this
issue because he failed to introduce into evidence the substitute for return that he
purportedly…
IRCCourt RulingsFeb 4, 1998related by meaning
ent under section 6654; and
(4) whether petitioner is liable for a penalty under section
6673. We hold for respondent on all issues. We also hold that petitioner is liable for a penalty under section 6673 and require
him to pay to the United States a penalty of $5,000. Unless
otherwise stated, section references are to…
IRCCourt RulingsMay 19, 2011related by meaning
ion 6662(a) and (b) (2).
Generally, section 6662(a) and (b) (1) authorizes the
Commissioner to impose a 20-percent penalty on the portion of an
- 72 - underpayment of income tax attributable to negligence or
disregard of rules or regulations. The term "negligence"
includes any failure to make.a reasonable attempt to co…
89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction IRCProposed Rules (FR)Proposed Mar 25, 2024
…including accuracy-related penalties under section 6662 or section 6662A, the penalty under section 6694 for understatements of a taxpayer's liability by a tax return preparer, the penalty under section 6700 for promoting abusive tax shelters, and the penalty under section 6701 for aiding and abetting understatement of…
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…
88 FR 37186 — Malta Personal Retirement Scheme Listed Transaction IRCProposed Rules (FR)Proposed Jun 7, 2023
…transactions, including accuracy-related penalties under section 6662 or section 6662A, the section 6694 penalty for understatements of a taxpayer's liability by a tax return preparer, and the section 6677 penalty for the failure to timely report certain transactions with, and ownership of, foreign trusts.
IRCCourt RulingsSep 15, 2005related by meaning
Court, the two cases were
consolidated for hearing on the motions to dismiss. The hearing
was held on November 29, 2004, in San Francisco, California. Discussion
Section 6033(a)(1) requires an organization exempt from
taxation under section 501(a) to file."an annual return, stating
specifically the ite s of gross incom…
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…
Notice 2007-83 — Abusive trust arrangements; cash value life insurance; welfare benefits. This notice identifies certain trust arrangements that claim to be welfare benefit fun… IRCNoticesNov 5, 2007
…is transaction or substantially similar transactions (including the return preparer penalty under § 6694, the promoter penalty under § 6700, and the aiding and abetting penalty under § 6701).
Further, under § 6501(c)(10), the period of limitations on assessment may be extended beyond the general three-year period of li…
IRCCourt RulingsMar 14, 2019related by meaning
ho conducted petitioner's CDP hearing, a USPS document relating to the
notice of deficiency for 2012, and a copy of this Court's order and decision in Wesley v. Commissioner, docket No. 6560-14L.
At trial petitioner offered and we admitted into evidence a screen shot of
information he had downloaded from the USPS track…
Notice 2007-84 — Post-retirement medical and life insurance benefits; nondiscrimination; welfare benefit funds. This notice alerts taxpayers that the tax treatment of trusts pr… IRCNoticesNov 5, 2007
…orting of these arrangements or similar arrangements (including the return preparer penalty under § 6694, the promoter penalty under § 6700, and the aiding and abetting penalty under § 6701).
The above rules apply whether the trust used to provide benefits under the arrangement is a taxable trust or a VEBA. While the t…
IRCRegulationsDec 30, 2016related by meaning
(a) (a) [Reserved]
Notice 2005-87 — Application of regulations under section 415; plan amendments. This notice provides that when the final regulations under section 415 of the Code are published… IRCNoticesDec 12, 2005
…uate disclosure for purposes of reducing an understatement of income tax under sections 6662(d) and 6694(a) of the Code. Rev. Proc. 2004-73 updated.
Announcement 2005-87 Announcement 2005-87
The purpose of this announcement is to formally announce the Compliance Assurance Process (CAP) pilot program for large business …
ERISARegulationsSep 1, 2017related by meaning
(e) (e) Transactions with fiduciaries
Notice 2004-8 — Roth IRAs; abuses; listed transactions. This notice describes certain transactions that are being entered into by individuals, their Roth IRAs, and their busin… IRCNoticesJan 26, 2004
…is transaction or substantially similar transactions, including the return preparer penalty under § 6694, the promoter penalty under § 6700, and the aiding and abetting penalty under § 6701.
The Service and the Treasury recognize that some taxpayers may have filed tax returns taking the position that they were entitled…
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.
IRCCourt RulingsOct 9, 2007related by meaning
ers . In response to
our leniency, petitioner once again ignored our Rules and our
order .
-5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a
sanction pursuant to Rule 123(b) . See Stringer v . Commissioner ,
84 T .C . 693, 704-705 (1985), affd . withou…