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Go to 29 U.S.C. § 6621 (not yet in the library — opens the official source)
75 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992related by meaning
    operly deducted, and there were no overstatements of pension liabilities. Therefore, for those six cases, there are no section 6659A additions to tax. In the remaining two cases, Boren Steel and Fox, we find for respondent in part; therefore, additions to tax under section 6659A may result. However, we do not have suff…
  2. Treas. Reg. § 1.501(r)-6(b)(1)(iv)(C) — Billing and collection.
    IRCRegulationsJul 12, 2016
    …aser is prohibited from charging interest on the debt in excess of the rate in effect under section 6621(a)(2) at the time the debt is sold (or such other interest rate set by notice or other guidance published in the Internal Revenue Bulletin);
  3. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
    )(2)(iv), designating the example as paragraph (d)(2)(iv)(A); 3. Revising newly designated paragraph (d)(2)(iv)(A) and adding paragraph (d)(2)(iv)(B); 4. Revising paragraphs (e)(1) and (e)(3)(i); and 5. Adding paragraph (h). The revisions and additions read as follows: § 1.6050I-1 Returns relating to cash in excess of …
  4. 29 C.F.R. § 2510.3-102(d)(3)(ii)(A) — Definition of “plan assets”—participant contributions.
    ERISARegulationsJan 1, 2017
    …f return; or (d)(3)(ii)(B) (B) Interest at a rate equal to the underpayment rate defined in section 6621(a)(2) of the Internal Revenue Code from the date on which such contributions were paid to, or withheld by, the employer until such money is fully restored to the plan.
  5. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    ions, this Court concludes that a section 6673 penalty of $500 is appropriate. It is "inappropriate that taxpayers who promptly pay their taxes should have the cost of Government and tax collection improperly increased by citizens apparently unwilling to obey the law or shoulder their assigned share of the Government c…
  6. 29 C.F.R. § 2550.401c-1(h)(52)(iii)(A) — Definition of “plan assets”—insurance company general accounts.
    ERISARegulationsAug 12, 2025
    … paragraph (i)(5)(ii) of this section at the “underpayment rate” as set forth in 26 U.S.C. sections 6621 and 6622. Such interest must be paid within the earlier of 60 days of detection by the insurer or sixty days following receipt of written notice of non-compliance from the plan.
  7. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    er 1 as determined under subsection (e) by substituting — (i) in paragraph (1)(A), “200 percent” for “150 percent” . . . . 2. Section 6662: Discussion Section 6662(a) is a generally applicable provision through which all accuracy-related penalties are imposed on underpayments of tax. Section 6662(b) lists the penalizab…
  8. 81 FR 47534 — Proposed Revision of Annual Information Return/Reports
    ERISAProposed Rules (FR)Proposed Jul 21, 2016
    …,” is the amortization base eligible for amortization using interest rates applicable under section 6621(b) of the Code for years beginning after 2007? ☐ Yes ☐ No 8(e) [Current] If box 5h is checked or Line 8c is “Yes,” enter the difference between the minimum required contribution for the year and the minimum that wou…
  9. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …x under section 6651(a) for failure to file timely its 1992 Federal income tax return and a section 6621 increased rate of interest on its 1991 deficiency as to interest accruing after July 20, 1995. Each petitioner petitioned the Court to redetermine respondent’s determinations. Respondent’s notices of deficiency - 5 …
  10. 89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction
    IRCProposed Rules (FR)Proposed Mar 25, 2024related by meaning
    ccordance with the regulations under section 6011, the taxpayer is subject to an increased penalty rate equal to 30 percent of the understatement. See section 6662A(c). Section 6662A(b)(2) provides that section 6662A applies to any item that is attributable to any listed transaction and any reportable transaction (othe…
  11. T.C. Memo. 2017-136 — David D. Pritchard v. Commissioner
    IRCCourt RulingsJul 10, 2017
    …w look generally at reasonable cause. The undersigned [petitioners] spent 20 years fighting section 6621 penalties and valuation penalties associated with the infamous FoodSource cases. * * * All those taxpayers wanted to pay the taxes and the interest; it was the penalties that made the bills onerous. * * * These are …
  12. Treas. Reg. § 301.6652-1(a)(1)(iii) — Failure to file certain information returns.
    IRCRegulationsDec 19, 2016related by meaning
    (a)(1)(iii) (iii) Section 6049(a)(1), relating to information returns with respect to payments of interest aggregating $10 or more in a calendar year, in effect with respect to payments made after December 31, 1962, and the regulations under such section, within the time prescribed for filing such statement (determined…
  13. T.C. Memo. 2000-266 — Lester L. & Susan P. Samford v. Commissioner
    IRCCourt RulingsAug 24, 2000
    …percent of the interest due on the deficiency and that the increased interest provisions of section 6621(c) applied. Assuming that the adjustments pertaining to SLA are properly before this Court in this proceeding, petitioners and respondent have reached an agreement as to the deficiency and additions to tax. The issu…
  14. 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…
  15. T.C. Summary Opinion 2005-80 — Harald Berrey v. Commissioner
    IRCCourt RulingsJun 9, 2005
    …e added to the tax an amount determined by applying the underpayment rate established under section 6621 to the amount of the underpayment - 12 - for the period of the underpayment. Unless the taxpayer demonstrates that one of the statutory exceptions applies, imposition of the section 6654(a) addition to tax is mandat…
  16. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997related by meaning
    Motion for a Section 6673 Penalty Respondent submitted a motion for the imposition of a penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an amount not to exceed $25,000 whenever it appears that the taxpayer's position in a proceeding is frivolous,…
  17. 81 FR 71019 — Electronic Notice of Liquidation
    IRCProposed Rules (FR)Proposed Oct 14, 2016related by meaning
    a statute or court order, to liquidate the entry within 90 days from when the suspension is removed, CBP is proposing to remove section 159.12(f)(2). Section 173.4a provides for the correction of clerical errors prior to liquidation. The section implements section 520 of the Tariff Act of 1930, as amended (19 U.S.C. 1…
  18. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …e to the Tax Court Rules of Practice and Procedure. and 6661, and additional interest under section 6621(c). 2 By agreement of the parties, resolution of petitioners' liabilities for the additions to tax and additional interest has been reserved for other proceedings. In five other cases, respondent determined administ…
  19. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    t C. Slaton purports to extend the period of limitations for 1983 only. Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
  20. 89 FR 25550 — Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements; Correction
    IRCProposed Rules (FR)Proposed Apr 11, 2024related by meaning
    eceived by October 30, 2023. ADDRESSES: Commenters were strongly encouraged to submit public comments electronically. FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, the Office of Associate Chief Counsel (Passthroughs & Special Industries) at (202) 317-6853 (not a toll-free number); concerning sub…