IRCCourt RulingsMar 3, 2016related by meaning
n the return of the
relevant facts affecting the item's tax treatment and there is a reasonable basis for
the taxpayer's treatment of the item.
- 10 - [*10] Here, the understatement of income tax is greater than $5,000. Thus, the
understatement is substantial for purposes of the section 6662(a) accuracy-related
penalty…
90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Aug 15, 2025related by meaning
in § 4233.3 and include a statement under penalties of perjury that the plan sponsor must submit with the signed and dated application for partition. PBGC is amending paragraph (b) of § 4233.3 to better comply with the affidavit requirements prescribed by the Department of Justice for perjury cases under 28 U.S.C. 174…
IRCCourt RulingsApr 2, 2020related by meaning
ded
because he and his wife were induced to sign it through fraud or
misrepresentation. As we explain below, though, this issue is not properly before the Court. See infra pt. I, pp. 39-40.
Sixth, Goldberg argues that he is entitled to abatement of interest under
section 6404(e)(1). As we explain below, this issue is p…
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…
I.R.C. § 6701(d) — Penalties for aiding and abetting understatement of tax liability IRCCode / StatuteJan 4, 1995related by meaning
(d) (d) Taxpayer not required to have knowledge Subsection (a) shall apply whether or not the understatement is with the knowledge or consent of the persons authorized or required to present the return, affidavit, claim, or other document.
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…
Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona… IRCNoticesModified Dec 22, 2008
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
IRCCourt RulingsNov 25, 2002related by meaning
ot entitled to IRA contribution
deductions because they did not substantiate their IRA
deductions. Finally, respondent determined that petitioners are liable for an accuracy-related penalty due to a substantial
understatement of income tax.
Discussion
In general, the determinations of the Commissioner in a
notice of de…
Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4… IRCNoticesObsolete Dec 26, 2007
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
IRCCourt RulingsDec 2, 2013related by meaning
ec. 6662(d). Here the understatement of $6,949 is substantial because it
exceeds $5,000 and is greater than 10% of the tax required to be shown on the return. Consequently, respondent has carried his burden of production. As a
result, petitioners now bear the burden to show that an exception to the penalty
applies. See…
Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr… IRCAnnouncementsMay 9, 2005
…ALTH PLANS
Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
IRCCourt RulingsJan 2, 2025related by meaning
cluding false returns), (10) failing to file returns, and (11) dealing in
12
The revenue agent (RA) determined to assert the fraud penalty against Mr. Hutcheson. Before respondent issued the Notice of Deficiency, the RA’s immediate
supervisor approved the RA’s determination in writing as required by section 6751(b).
Se…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…9
0
0
0
4,139,119
4,139,119
4
61.7
38.3
34.4
0
0
0
3,977,383
3,977,383
5
62.3
37.7
33.8
0
0
0
3,898,691
3,898,691
6
62.7
37.3
33.4
0
0
0
3,860,403
3,860,403
7
62.8
37.2
33.3
0
0
0
3,841,774
3,841,774
8
62.9
37.1
33.2
0
0
0
3,832,710
3,832,710
9
63.0
37.0
33.1
0
0
0
3,828,300
3,828,300
10
63.0
37.0
33.1
0
0
0
3,826,154
…
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
IRCPrivate Letter RulingsJul 26, 2013
…udible in
the beneficiary’s gross income as income in respect of a decedent within the meaning of
§ 691. If the death benefit is instead received in the form of a series of periodic
payments in accordance with § 72(s), the amounts received are likewise includible in
the beneficiary’s gross income (in an amount determin…
IRCCourt RulingsDec 22, 2008related by meaning
foregoing quoted terms are specially defined and used
under the "Public Salary Tax Act of 1939" ;
3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor
"taxpayer," nor "non-resident alien," nor any other
"legal entity" "made liable for" or "subject to" any
"internal reve…
IRCCourt RulingsJan 17, 2024related by meaning
at 568 – 69. Petitioner has not explained why the result should be different here.
Petitioner assert s that the placement of section 4973 in the Code i s “irrelevant,” citing section 7806(b) for the proposition that “[n]o inference, implication, or presumption of legislative construction shall be . . .
made by reason …
IRCCourt RulingsMar 4, 2010related by meaning
(2002) . We sustain
respondent's determinations as to the additions to tax under
sections 6651(a)(1) and (2) and 6654(a) .
IV . Section 6673 Penalt y Respondent has moved to impose a penalty under section
6673(a)(1), which authorizes this Court to require a taxpayer to
pay to the United States a penalty not in excess o…
IRCCourt RulingsAug 24, 1981related by meaning
in 1976 within the meaning of the statutory limitation and, hence, is not entitled to a deduction under section 219 for the payment to an IRA in 1976. Section 4973 imposes an excise tax of 6 percent on "excess contributions” made to án IRA during the taxable year. Since petitioner is not entitled to a deduction under s…
IRCCourt RulingsSep 1, 2016related by meaning
Penalty
Respondent determined an accuracy-related penalty of $5,281 for a
substantial understatement of Federal income tax. Section 6662(a) and (b)(2) authorizes a 20% penalty on the portion of an underpayment of income tax
attributable to a substantial understatement of income tax. Under section 7491(c),
the Commissio…