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81 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. PLR 200519047 — Non-Exempt Funds or Plans
    IRCPrivate Letter RulingsMay 13, 2005
    … of the trust, the value of such interest exceeds 5 percent of the value of such portion. Section 1.671-4 of the Regulations sets out requirements for the reporting of items of income, deduction, and credits when a taxpayer is regarded as the owner of a portion of a trust pursuant to section 671 of the Code. A Particip…
  2. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    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…
  3. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    n 6662(a) and (b)(1) and (2), a taxpayer may be liable for a penalty of20% 5 Over petitioner's objection respondent introduced a literal transcript of account for petitioner's 2010 tax year. The literal transcript contains no reference to any SFRs. Even if it did, the literal transcript does not establish that the requ…
  4. PLR 199930021 — Payments Benefitting Independent Contractors
    IRCPrivate Letter RulingsJul 30, 1999
    …erefore, are not associates in a joint enterprise for the conduct of business for profit. -4Section 671 of the Code provides that where a grantor shall be treated as the owner of any portion of a trust under subpart E, part I, subchapter J, chapter 1 of the Code, there shall then be included in computing the taxable in…
  5. T.C. Memo. 2016-37 — Syed Navaid v. Commissioner
    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…
  6. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    n to compel documents from AEGON USA, Mr. Smith’s client, and (2) respondent’s offer of evidence as to certain marketing materials and other evidence. Petitioners argue that their positions are meritorious. Petitioners assert that respondent’s motion to impose sanctions against each of them is frivolous and that the Co…
  7. 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…
  8. T.C. Memo. 1999-369 — Westchester Plastic Surgical Associates, P.C. v. Commissioner
    IRCCourt RulingsNov 5, 1999
    …ank of New York for account No. 015-283294 was as follows: Date Withdrawal Deposit Balance 7/31/90 $671.18 $671.18 8/16/90 1,600.00 2,271.18 4/04/91 74.20 2,345.38 Discussion This Court may exercise jurisdiction over a declaratory judgment action if there is an actual controversy involving a determination by the Secret…
  9. T.C. Memo. 1997-8 — Gary Benton & Karen Ruth Logsdon v. Commissioner
    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…
  10. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    ns were made negligently or intentionally.”) (emphasis added); see Mathews v. Chevron Corp., 362 F.3d 1172, 1183 (9th Cir. 2004). Back to Citation 37.  84 FR 33348, note 303. The Department observes that this requirement is also consistent with, for example, the requirement under section 206 of the Advisers Act, which …
  11. 75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable…
    IRCFinal Rules (FR)Jul 19, 2010
    …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.
  12. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016related by meaning
    tion 6011(a) requires that any person made liable for a tax or with respect to its collection "shall make a return or statement according to the forms and regulations prescribed by the [Treasury] Secretary." "The return or statement shall include therein the information required by the applicable regulations or forms."…
  13. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …ales agent. The labor rate is applied in the following calculation: 4,061 burden hours × $165.29 ≉ $671,212. The mailing cost is estimated as: (24,365 requests × 28.2% receiving disclosures via mail) ≉ 6,871 rollovers resulting in a paper disclosure × [$0.68 postage + ($0.05 per page × 2 pages)] + (2 minutes ÷ 60 minut…
  14. 89 FR 43636 — Abandoned Plan Regulations
    ERISAFinal Rules (FR)May 17, 2024
    …lerical staff time with an equivalent cost burden of $79,503 (1,253 hours × $63.45 per hour), and 1,671 hours (2,506 plans × 40 minutes) of an accountant's time with an equivalent cost burden of $195,234 (1,671 hours × $116.86 per hour) for a total estimated equivalent cost burden of $274,737. Based upon recent filing …
  15. T.C. Memo. 2022-101 — William T. Ashford v. Commissioner
    IRCCourt RulingsSep 29, 2022related by meaning
    at trial that he had filed a return for 2012 showing tax due. Although his 2013 account transcript r eflects a withholding credit of $320 , petitioner has neither argued nor shown that his 2013 withholding equaled or exceeded the amount of tax shown on his 2012 return. As for 2014, petitioner’s required annual payment …
  16. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979
    …ts entirety, if the trust income is less than $16,502) is includable in petitioner’s income. Sec. 1.671-3(a)(3), Income Tax Regs. The portion of each item which is attributable to petitioner is treated as if it had been received or paid directly by her. Sec. 1.671-2(c), Income Tax Regs. Where, in any year (such as 1972…
  17. T.C. Summary Opinion 2009-156 — Dean Gochis v. Commissioner
    IRCCourt RulingsOct 13, 2009related by meaning
    Section 72(t) Additional Ta x Section 72(t) imposes an additional tax on an individual retirement plan distribution equal to 10 percent of the amount .included in gross income, subject to certain exceptions . Because the ASLAC distribution is not includable in petitioner's gross income, petitioner is not liable for th…
  18. 80 T.C. 789; 80 T.C. No. 40 — Benson v. Commissioner
    IRCCourt RulingsApr 26, 1983
    …reof to the extent such income would be taken into account in computing individual income tax. Sec. 671. Respondent asserts, and petitioner denies, that Marion must be deemed the owner of the income of the ABC trust for purposes of sections 677 and 671.
  19. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    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…
  20. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    IRCCourt RulingsMar 22, 2007related by meaning
    ddition to tax must be sustained. Section 6673(a)(1) authorizes the Court to require a taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or groundless or the taxpayer has instituted or pursued the proceeding primarily for delay. Respondent has n…