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71 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2016-37 — Syed Navaid v. Commissioner
    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…
  2. 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…
  3. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    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…
  4. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    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…
  5. 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.
  6. 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…
  7. 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 …
  8. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    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…
  9. 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 …
  10. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    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…
  11. 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 …
  12. T.C. Memo. 2025-1 — Matthew D. Hutcheson & Annette Hutcheson v. Commissioner
    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…
  13. 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 …
  14. T.C. Memo. 2015-47 — Balvin Anthony McKnight v. Commissioner
    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…
  15. PLR 201330016 — Required Distributions Where Holder Dies
    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…
  16. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    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…
  17. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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 …
  18. T.C. Memo. 2010-42 — Scott Ray Holmes v. Commissioner
    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…
  19. 77 T.C. 477 — Chapman v. Commissioner
    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…
  20. T.C. Summary Opinion 2016-52 — Bruce W. Peterson & Lisa A. Peterson v. Commissioner
    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…