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76 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ds of thousands of dollars in DISC commissions each year from a well-established business, and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount. -28IV. Section 6662(a) Penalty Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
  2. 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…
  3. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
  4. 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…
  5. 74 T.C. 651 — Judd v. Commissioner
    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…
  6. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  7. 119 T.C. No. 6 — Robert Ancira v. Commissioner
    IRCCourt RulingsSep 24, 2002related by meaning
    titioner is not liable for the sec. 6662 penalty. 3 S.K. apparently stands for Smoothie King, which we gather was the trade name of a product. OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 The Court agrees with and…
  8. PLR 201017056 — Tax on Prohibited Transactions
    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.,…
  9. 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…
  10. 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/​.
  11. 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…
  12. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    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…
  13. PBGC Op. Ltr. 1994-8 — Withdrawal liability
    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…
  14. 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 …
  15. 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…
  16. 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 …
  17. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    required to disclose in that return all of the assets that it held at the end of 2005 and the respective yearend values of all of those assets. - 7 - Under IRC section 4979[A](e)(2)(C), all the deemed owned shares of all the disqualified persons with respect to the Law Office of John H Eggertsen P. C. Employee Stock O…
  18. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    …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/​. Back to Citation 340.   See, for example, the proposed 2027 HHS notice of benefit and payment parameters (9…
  19. T.C. Memo. 2013-42 — Roger Phillips v. Commissioner
    IRCCourt RulingsFeb 7, 2013related by meaning
    Sec. 6651(a)(2), (g)(2); Cabirac v. Commissioner, 120 T.C. 163, 170 (2003). When a taxpayer has not filed a return, the section 6651(a)(2) addition to tax may not be imposed unless the Secretary has prepared a substitute for return that satisfies the requirements of section 6020(b). See Wheeler v. Commissioner, 127 T.C…
  20. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    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…