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61. 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…
62. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …tablish that the Comm issioner employed an unreasonable methodology to reach his result. See id. at 203. A taxpayer may do this by showing that the Commissioner ’ s methodology implicated significant legal error or that the Commissioner implemented the methodology in an unreasonable manner ( e.g., by employing erroneou…
63. T.C. Memo. 2004-130 — Ralf Zacky v. Commissioner
    IRCCourt RulingsMay 27, 2004
    as of March 31, 1995, “Other” investments of $203,241. Respondent determined that these investments were the three loans, that each of the three loans was a prohibited transaction under section 4975, and that the principal of the three loans totaled $203,241 as of January 1, 1996. Respondent also determined that a “sta…
64. 82 FR 16902 — Definition of the Term “Fiduciary”; Conflict of Interest Rule-Retirement Investment Advice; Best Interest Contract Exemption (Prohibited Transaction Exemption …
    ERISAFinal Rules (FR)Apr 7, 2017related by meaning
    ility date is subject to the Congressional Review Act (CRA) provisions of the Small Business Regulatory Enforcement Fairness Act of 1996 (5 U.S.C. 801 et seq.) and will be transmitted to Congress and the Comptroller General for review. The final rule is a “major rule” as that term is defined in 5 U.S.C. 804, because it…