Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to I.R.C. § 7122 (not yet in the library — opens the official source)
66 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 29 C.F.R. § 2570.111(n) — Definitions.
    ERISARegulationsJan 1, 2017related by meaning
    (n) (n) 502(c)(6) civil penalty proceeding means an adjudicatory proceeding relating to the assessment of a civil penalty provided for in section 502(c)(6) of ERISA;
  2. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    ng in a change in beneficial interests causes the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612. (18) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions fr…
  3. T.C. Summary Opinion 2003-47 — Debra Sue Tussey v. Commissioner
    IRCCourt RulingsApr 30, 2003
    …ess has provided that closing agreements under section 7121 and compromise agreements under section 7122 are the exclusive means by which the IRS can administratively settle civil tax disputes with finality. See Botany Worsted Mills v. United States , 278 U.S. 282, 288 (1929); Estate of Meyer v. Commissioner , 58 T.C. …
  4. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  5. 75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Jun 16, 2010related by meaning
    URE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * *. Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows: § 301.6404-0 Table of Contents. * * * * * § 301.6404-4 Suspension of interest and c…
  6. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024related by meaning
    icipation. Id. Thus, even though the withdrawal from the taxpayer’s Keogh account was involuntary and the funds were paid directly to the USA pursuant to the Commissioner’s levy, the taxpayer was deemed to constructively receive the funds under section 72(m)(4)(A). 4 In Murillo , 75 T.C.M. (CCH) at 1564, the taxpayer p…
  7. ERISACode / StatuteJan 4, 1995related by meaning
    (a)(6) (6) such other matter as any of the committees referred to in section 1221 of this title may refer to it.
  8. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    ial Institution, an entity in the same Controlled Group as the Financial Institution, or an Investment Professional has been: (1) Convicted by either: (A) a U.S. Federal or State court as a result of any felony involving abuse or misuse of such person's employee benefit plan position or employment, or position or emplo…
  9. Rev. Proc. 2007-71 — Tax-sheltered annuities; written program; public schools; model amendments. This procedure sets forth model amendments that may be adopted in order to satisfy …
    IRCRevenue ProceduresDec 17, 2007related by meaning
    a Participant under this Section 2.2(b) shall file a designation of Beneficiary with the Funding Vehicle or Vehicles to which contributions are made. (2) Right to File a Different Election; Notice to Employee. This Section 2.2(b) shall not apply to the extent an Employee files an election for a different percentage re…
  10. 29 C.F.R. § 2560.502c-2(a) — Civil penalties under section 502(c)(2).
    ERISARegulationsJan 1, 2017related by meaning
    (a) (a) In general. (a)(1) (1) Pursuant to the authority granted the Secretary under section 502(c)(2) of the Employee Retirement Income Security Act of 1974, as amended (the Act), the administrator (within the meaning of section 3(16)(A)) of an employee benefit plan (within the meaning of section 3(3) and § 2510.3-1, …
  11. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    Petitioners’ third prong asserts that, in any event, the lump-sum payment and the annuity payments to which he was entitled came from separate accounts and that, consequently, the former payment was not received under an “annuity contract” so as to make section 72(e) applicable. Initially, we note that section 1.72-2(a…
  12. T.C. Memo. 2003-156 — Michael W. Duncan v. Commissioner
    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…
  13. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    nd.8 SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg g, Hyd…
  14. T.C. Memo. 2016-33 — Sally M. Costello v. Commissioner
    IRCCourt RulingsMar 1, 2016
    … any adjustment to correct the error is - 9 - [*9] barred by operation of law (other than a section 7122 compromise or these mitigation provisions). Sec. 1311(a); see Beaudry Motor Co., 98 F.3d at 1168. Respondent, as the party asserting mitigation, has the burden of showing its applicability. See Bradford v. Commissio…
  15. 75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac…
    IRCFinal Rules (FR)Jul 6, 2010related by meaning
    r tax-favored savings arrangements, contact Cathy Pastor at (202) 622-6090 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Paperwork Reduction Act The collection of information contained in these final regulations has been reviewed and approved by the Office of Management and Budget in accordance with the Paperwork…
  16. ERISA § 3003(c) (29 U.S.C. § 1203) — Procedures in connection with prohibited transactions
    ERISACode / StatuteJan 4, 1995related by meaning
    (c) (c) Transmission of information to Secretary of the Treasury Whenever the Secretary of Labor obtains information indicating that a party-in-interest or disqualified person is violating section 1106 of this title, he shall transmit such information to the Secretary of the Treasury.
  17. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    ce 2002-8 supra,-are unrêasonable or incorrect. Furthermore, on a motion f r summary judgm t thàt is prð];>erly'm de and supported, the o poeing party must 9et forth specific facts showing that there is a genuine issue fo trial. Rule 121(d) . Petitioner does not allege thathe has any evidence that wo ld sat-isfy 'that …
  18. 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…
  19. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    ccuracy-related penalty under section 6662. OPINION I. Preliminary Matters Petitioner argues that respondent bears the burden of proof with respect to his unreported income for both tax years. For the reasons below, we disagree. Generally, the Commissioner's determinations in a notice of deficiency are presumed correct…
  20. 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…