167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
e rules regarding other penalties listed in section 6662(b).
See § 6662(c), (e)(1), (f)(1), (g)(1), (j)(1), (k) (each beginning with the phrase “[f]or purposes of this section” and explaining the meaning of terms such as “negligence,”
“substantial valuation misstatement,” and so on).
11
Section 6664(c) is titled “ Reas…
IRCCourt RulingsJul 24, 2006related by meaning
petitioners' Federal income tax for 2002 and determined that
petitioners are liable for the accuracy-related penalty under
section 6662(a)' for 2002 . There are two issues for decision . The first issue is
whether a $977,888 distribution petitioner Charlotte Gee
(petitioner) received in 2002 from an individual retireme…
IRCCourt RulingsDec 15, 2009related by meaning
series of substantially
equal periodic payments . Petitioners allege that Ms . Welker "is
a cancer survivor and left her job as a result of the cancer treatment ." Petitioners did not appear at trial, and the case
was submitted on the basis of the parties' stipulation of facts .
Discussion
In general, the Commissioner'…
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
ble and Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A). (56) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for…
75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable… IRCFinal Rules (FR)Jul 19, 2010
…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.
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…
IRCCourt RulingsFeb 24, 2011related by meaning
se determinations are erroneous. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).
Pursuant to section 7491(a) (1), the burden of proof as to factual matters may shift from the taxpayer to the Commissioner
under certain circumstances. Petitioner did not allege that
section 7491 applies, nor did she introduce t…
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…
IRCCourt RulingsDec 2, 1981
…receipt of a "notice of determination.” On the same date, petitioner filed petitions in docket Nos. 752-81 and 751-81 contesting the deficiency determinations for the taxable years ending May 31, 1974, and May 31, 1975, respectively. All three petitions were filed as a result of receipt of one statutory notice of defic…
IRCCourt RulingsJan 3, 2017related by meaning
e Commissioner's determinations are erroneous, see Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). This burden of production remains on the taxpayer even with respect to the additional tax under section 72(t) because the
section 72(t) additional tax is a "tax" and not a "penalty, addition to tax, or
addition…
PBGCRegulationsJan 1, 2017
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
IRCCourt RulingsFeb 28, 2024related by meaning
004 made
an excess contribution of $25,132,892 to his individual retirement account (IRA). Section 4973(a)
1
imposes an excise tax “in an amount equal to 6 percent of the amount of the excess contributions” that a taxpayer
makes to an IRA in any given year. This tax continues to apply for future years, until such time …
PBGCRegulationsJan 1, 2017
…t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
PBGCRegulationsJan 22, 2018
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
IRCCourt RulingsJul 5, 2017related by meaning
5, and bore a postmark indicating that it was mailed by FedEx Standard
Overnight service on July 6, 2015. Since the petition was mailed timely using a - 6 -
[*6] designated private delivery service, see Notice 2015-38, 2015-21 I.R.B. 984,
it is treated as filed timely, see sec. 7502(a), (f).
Discussion
I. Overview
Gene…
IRCCourt RulingsSep 27, 1990related by meaning
. United States, 872 F.2d 564, 568-570 (3d Cir. 1989).
Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
… a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information.
3
Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here:
https://www.bls.gov/news.release/pdf/jolts.pd…
IRCCourt RulingsJan 28, 2014related by meaning
her authority that would distinguish the Martin cases from the issue
presented before the Court. Accordingly, petitioners have not met their burden of proving that the weight of the authorities supporting the treatment of the IRA
- 25 -
[*25] distributions is substantial in relation to the weight of the authorities
sup…
IRCCourt RulingsOct 16, 2017related by meaning
ord contained no loan documents or other evidence showing that the
distribution was evidenced by a legally enforceable agreement).
III. Additional Tax Section 72(t)(1) imposes a 10% additional tax on early distributions from
qualified retirement plans. Section 72(t)(2), however, sets forth specific
exceptions to the ge…
IRCPrivate Letter RulingsMar 2, 2001related by meaning
n believes a court would find section 4975 to be punitive in nature
and, therefore, considered a penalty under the Bankruptcy Code. See
, e.g. , In re MMR Holding Corp. , 1998 Bankr. LEXIS 1132 (Bankr. M.D. La. 1998) (for purposes
of I.R.C. § 6601, section 4975(a) is a penalty because its aim is to punish wrongful
cond…