89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAFinal Rules (FR)Jan 24, 2024related by meaning
nt must promptly notify the Department in writing if it learns that a material fact or representation has been omitted from the exemption application. (b) If, at any time during the pendency of an exemption application, the applicant or any other party in interest who would participate in the exemption transaction beco…
IRCCourt RulingsJun 16, 2011
…for respondent.
MEN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7463 of the Internal Revenue Code in
effect when the petition was filed.1 Pursuant to section
7463(b), the decision to be entered is not reviewable by any
Unless ot herwise indicated, all subsequent section
references ar…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.3 of this title.
IRCCourt RulingsSep 23, 2019
…espondent.
SUMMARY OPINION
COLVIN, Judge: This case was heard pursuant to the provisions of section
7463 of the Internal Revenue Code in effect when the petition was filed.¹
¹Section references are to the Internal Revenue Code in effect for the year in
issue. Rule references are to the Tax Court Rules of Practice and P…
IRCCourt RulingsAug 1, 2011
…nt .
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect when the petition was filed.1 Pursuant to
section 7463 (b) , the decision to be entered is not reviewable by
1Unless otherwise indicated, subsequent section references
are to t…
75 FR 46844 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Aug 4, 2010related by meaning
on 53.6071-1 is amended by revising paragraph (g)(3) to read as follows:
§ 53.6071-1
Time for filing returns.
* * * * *
(g) * * *
(3)
Transition rule. A Form 4720, for a section 4965 tax that was due on or before October 4, 2007, will be deemed to have been filed on the due date if it was filed by October 4, 2007, and …
IRCCourt RulingsAug 8, 2019
…MMARY OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to the
provisions of section 7463 of the Internal Revenue Code in effect when the
SERVED Aug 08 2019
- 2 -
petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not
reviewable by any other court, and this opinion shall not …
IRCCourt RulingsJan 2, 2020related by meaning
er. Mrs. Gebman did not provide any evidence that persuades us that
she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file
amendment to petition filed August 28, 2019.
VI. Section 6662(a) Penalties
Section 6662(a) an…
IRCCourt RulingsJun 28, 2017
…ondent.
SUMMARY OPINION
GERBER, Judge: This case is was heard pursuant to the provisions of
section 7463 of the Internal Revenue Code in effect when the petition was filed.¹
¹Unless otherwise indicated, all section references are to the Internal
Revenue Code in effect for the year in issue, and all Rule references are …
IRCCourt RulingsApr 3, 2018
…pondent.
SUMMARY OPINION
THORNTON, Judge: This case was heard pursuant to the provisions of
section 7463 of the Internal Revenue Code in effect when the petition was filed.¹
¹All subsequent section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the Tax Court …
IRCCourt RulingsJul 24, 2017
…espondent.
SUMMARY OPINION
JACOBS, Judge: This case was heard pursuant to the provisions of section
7463 of the Internal Revenue Code in effect when the petition was filed. Pursuant
to section 7463(b), the decision to be entered is not reviewable by any other court,
and this opinion shall not be treated as precedent fo…
IRCCourt RulingsJan 21, 2020
…espondent.
SUMMARY OPINION
RUWE, Judge: This case was brought pursuant to the provisions of section
7463 of the Internal Revenue Code in effect when the petition was filed.¹
¹Unless otherwise indicated, all section references are to the Internal
Revenue Code in effect for the year in issue, and all Rule references are …
IRCCourt RulingsAug 20, 2019
…SUMMARY OPINION
GUY, Special Trial Judge: This case was heard pursuant to the provisions
of section 7463 of the Internal Revenue Code in effect when the petition was
filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by
¹Unless otherwise indicated, section references are to the Internal R…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016related by meaning
note, Pub. L. 114-74 at § 701. Subparts H and I issued under 8 U.S.C. 1101(a)(15)(H)(i)(b) and (b1), 1182(n), 1182(t), and 1184; 29 U.S.C. 49
et seq.; sec 303(a)(8), Pub. L. 102-232, 105 Stat. 1733, 1748 (8 U.S.C. 1182 note); and Title IV, Pub. L. 105-277, 112 Stat. 2681; and 28 U.S.C. 2461 note, Pub. L. 114-74 at § 70…
IRCCourt RulingsOct 1, 2015
…SUMMARY OPINION
GUY, Special Trial Judge: This case was heard pursuant to the provisions
of section 7463 of the Internal Revenue Code in effect when the petition was
filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by
¹Unless otherwise indicated, section references are to the Internal R…
IRCCourt RulingsAug 9, 2016
…spondent.
SUMMARY OPINION
VASQUEZ, Judge: This case was heard pursuant to the provisions of
section 7463 of the Internal Revenue Code in effect when the petition was filed.
Pursuant to section 7463(b), the decision to be entered is not reviewable by any
other court, and this opinion shall not be treated as precedent fo…
IRCCourt RulingsJul 14, 2015
… respondent.
SUMMARY OPINION
PUGH, Judge: This case was heard pursuant to the provisions of section
7463 of the Internal Revenue Code in effect when the petition was filed.'
¹ Unless otherwise indicated, all subsequent section references are to the
Internal Revenue Code in effect for the year in issue.
SERVED JUL 1 4 2…
IRCCourt RulingsDec 2, 2013
…MMARY OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to the
provisions of section 7463 of the Internal Revenue Code in effect when the
SERVED DEC - 2 2013
- 2 -
petition was filed.i Pursuant to section 7463(b), the decision to be entered is not
reviewable by any other court, and this opinion shall not…
ERISARegulationsApr 8, 2024related by meaning
(f)(11)(i)(E) (E) Any felony or conspiracy involving the larceny, theft, robbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds or securities; or
(f)(11)(ii) (ii) A statement describing the applicable investigation, examination, litigation,…
IRCCourt RulingsFeb 23, 2015
…SUMMARY OPINION
GUY, Special Trial Judge: This case was heard pursuant to the provisions
of section 7463 of the Internal Revenue Code in effect when the petition was
filed.' Pursuant to section 7463(b), the decision to be entered is not reviewable by
¹Unless otherwise indicated, section references are to the Internal R…