84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCFinal Rules (FR)Nov 1, 2019
…
118.
12 U.S.C. 4802.
Back to Citation
119.
12 U.S.C. 4802(b)(2).
Back to Citation
120.
5 U.S.C. 801
et seq.
Back to Citation
121.
5 U.S.C. 801(a)(3).
Back to Citation
122.
5 U.S.C. 804(2).
Back to Citation
123.
IRCCourt RulingsMay 13, 1999
… employees for each
year was zero dollars, with the exception of 1987 in which
petitioner reported $801.01 as salaries and wages. Thus,
petitioner reported that it did not pay either Robert or Charlene
Peers any compensation for their services as officers of
petitioner, and that petitioner paid only $801.01 as salaries…
IRCCourt RulingsDec 2, 2010related by meaning
me to file a brief.
She.has continually tested this Court's patienceswith motions to
extend time to file and then ultimately failed to submit a brief. Petitioner is a member of the California State Bar and, as such,
should be sensitive to any actual or perceived abuse of the
judicial process. The Court directs petition…
IRCCourt RulingsMar 5, 2018
057 (9th Cir.
2014), T.C. Memo. 2012-106; see also Bank of N.Y. Mellon Corp. v.
Commissioner, 801 F.3d 104, 115 (2d Cir. 2015), 140 T.C. 15 (2013) and T.C. Memo. 2013-225. As the Court of Appeals has also noted, however, "the
economic substance doctrine is not a rigid two-step analysis, but instead focuses
holistically…
IRCCourt RulingsSep 22, 1998related by meaning
nerally presumed correct.
Rule 142(a); Welch v. Helvering
, 290 U.S. 111, 115 (1933).
Furthermore, every item of a person's gross income is subject to Federal income tax unless there is a statute or some rule of law
that exempts the person or the item from gross income. HCSC-
Laundry v. United States
, 450 U.S. 1, 5 (1…
IRCCourt RulingsDec 24, 1985
… the trust is not a veba, it is taxable as an insurance company, i.e., under subchapter L (sections 801 et seq.). Although the Internal Revenue Code does not define the term "insurance company,” the regulations provide the following guidance:
The term "insurance company” means a company whose primary and predominant bu…
IRCCourt RulingsMay 19, 2011related by meaning
ion 6662(a) and (b) (2).
Generally, section 6662(a) and (b) (1) authorizes the
Commissioner to impose a 20-percent penalty on the portion of an
- 72 - underpayment of income tax attributable to negligence or
disregard of rules or regulations. The term "negligence"
includes any failure to make.a reasonable attempt to co…
IRCCourt RulingsApr 19, 2004related by meaning
longed to petitioner when he
filed his bankruptcy petition is still encumbered in rem by a
Federal tax lien. Respondent argues that a State law cannot operate to divest or exempt petitioner’s section 401(k)
retirement account from the Federal tax lien. Respondent
contends that collection by levy is appropriate. We agre…
IRCCourt RulingsOct 19, 2010related by meaning
deficiency is presumed
correct, and the taxpayer bears the burden of proving that the
determination is improper. See Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). However, pursuant to section 7491(a),
the burden of proof on factual issues that affect the taxpayer's
tax liability may shift to the Commissio…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…ine and Post-Rule:
Default IRAs
144,664
166,262
184,775
197,117
203,288
209,459
215,630
218,715
221,801
221,801
1,983,512
Accounts with AP
94,032
176,417
249,441
299,357
324,685
350,261
376,083
389,086
402,152
402,152
3,063,666
AP Transfers
60,265
182,122
293,101
361,675
386,934
429,010
471,876
480,380
502,295
486,672
…
PBGCFinal Rules (FR)Jul 12, 2021
…tory Enforcement Fairness Act of 1996 (also known as the Congressional Review Act or CRA) (5 U.S.C. 801 et seq.), the Office of Management and Budget (OMB) has designated this interim final rule as a “major rule,” as defined by 5 U.S.C. 804(2)(a), which is a rule likely to result in an annual effect on the economy of $…
IRCCourt RulingsFeb 6, 2024related by meaning
Tax Court Rules of Practice and Procedure. Except where
otherwise indicated, all monetary amounts are rounded to the nearest dollar.
Served 02/06/24
2 [* 2 ] failure to file and failure to pay addition s to tax for petitioner’ s 2017
tax year .
2
T he issue s for decision are whether (1) petitioner is liable for tax
wi…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
… that denoted on the Schedule C that they were a discretionary trustee. Further, among these plans, 801 plans
( printed page 75931)
also reported that the discretionary trustee provided investment management services or received investment management fees paid directly or indirectly by the plan.[291]
Based on the range…
78 FR 20039 — Reportable Events and Certain Other Notification Requirements PBGCProposed Rules (FR)Proposed Apr 3, 2013related by meaning
e on the applicability and enforcement of ERISA section 4062(e). PBGC is currently giving careful consideration to the comments on that proposed rule. Back to Citation
32.
Such “non-statutory” contributions are not taken into account under ERISA section 303(k) and Code section 430(k), dealing with liens that arise bec…
88 FR 4900 — Special Financial Assistance by PBGC-Withdrawal Liability Condition Exception PBGCFinal Rules (FR)Jan 26, 2023
…tory Enforcement Fairness Act of 1996 (also known as the Congressional Review Act or CRA) (5 U.S.C. 801 et seq.), the Office of Management and Budget (OMB) has designated this final rule as a “major rule,” as defined by 5 U.S.C. 804(2)(a), which is a rule likely to result in an annual effect on the economy of $100 mill…
IRCCourt RulingsJan 6, 1997related by meaning
etitioners are liable for an
accuracy-related penalty of $4,870 pursuant to section 6662(a)
for 1991. Section 6662 imposes a 20-percent penalty on any portion of any underpayment that is attributable to any
substantial understatement of income tax. Sec. 6662(a)(2),
- 14 -
(b)(2). Respondent based the determination of t…
PBGCFinal Rules (FR)Jul 8, 2022
…tory Enforcement Fairness Act of 1996 (also known as the Congressional Review Act or CRA) (5 U.S.C. 801 et seq.), the Office of Management and Budget (OMB) has designated this final rule as a “major rule,” as defined by 5 U.S.C. 804(2)(a), which is a rule likely to result in an annual effect on the economy of $100 mill…
87 FR 80042 — Exception for Interests Held by Foreign Pension Funds IRCFinal Rules (FR)Dec 29, 2022related by meaning
ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development.
( printed page 80055) List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended a…
82 FR 47792 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…th Circuit disagreed and ruled in favor of religious nonprofit employers.
Dordt College
v.
Burwell, 801 F.3d 946, 949-50 (8th Cir. 2015) (relying on
Sharpe Holdings, Inc.
v.
U.S. Dep't of Health & Human Servs.,
801 F.3d 927 (8th Cir. 2015)).
On November 6, 2015, the U.S. Supreme Court granted certiorari in seven simila…
IRCCourt RulingsMar 3, 2016related by meaning
, petitioner tried to keep his tax records and IRS paperwork
for 10 years.
In 2001 petitioner ran a small pharmacy in addition to working at a Federal Government hospital. On April 19, 2001, he was charged, along with two other
codefendants, with diversion of pharmaceuticals from the Department of Veterans
Affairs, and…