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61. 83 FR 36417 — Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions
    IRCFinal Rules (FR)Jul 30, 2018related by meaning
    ted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business, and no comments were received. Drafting Information The principal author of these regulations is Charles Gorham of the Office of Associate Chief Counsel (Income Tax and Accounting). Other personnel fr…
62. 87 FR 52618 — Requirements Related to Surprise Billing
    IRCFinal Rules (FR)Aug 26, 2022
    …s Act.” U.S.C.-Brookings Schaeffer on Health Policy. (March 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 114.  2 U.S.C. 1501 et seq. (1995). Back to Citation 115.  See House Conf. Rep. No. 104-73…
63. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ause, petitioners must show that the assessment of the penalties is so harsh and oppressive as to transgress the constitutional limitation: See, e.g., McGehee Family Clinic v. Commissioner, T.C.:Memo. 2010-202. The penalty structure of section 6662A does not do so Petitioners also contend that their due process rights …
64. REG-117270-25 — Notice of Proposed Rulemaking
    IRCProposed Rules (FR)Proposed Mar 23, 2026related by meaning
    dent of Documents, U.S. Government Publishing Office, Washington, DC 20402, or by visiting the IRS website at http://www.irs.gov. Drafting Information The principal author of these proposed regulations is the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) at (202) 317-…
65. PLR 200109010 — Sale/Exchange
    IRCPrivate Letter RulingsMar 2, 2001related by meaning
    was to punish a pension plan sponsor for fa iling to fund a pension plan as required by ERISA. 518 U.S. at 225-26. The Court, thus, concluded that the section 4971 liab ility was a penalty not entitled to priority. Although the Supreme Court in CF&I addressed section 4971 rather than section 4975, Collection, Bankruptc…
66. 78 FR 218 — Shared Responsibility for Employers Regarding Health Coverage
    IRCProposed Rules (FR)Proposed Jan 2, 2013related by meaning
    and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, 26 CFR parts 1, 54, and 301 are proposed to be amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 2. Section 1.1361-4 is amen…
67. 89 FR 84079 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCFinal Rules (FR)Oct 21, 2024related by meaning
    icipated in the development of the regulation. List of Subjects in 26 CFR Part 31 Employment taxes Income taxes Penalties Pensions Railroad retirement Reporting and recordkeeping requirements Social security Unemployment compensation Adoption of Amendments to the Regulations Accordingly, 26 CFR part 31 is amended as fo…
68. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    urd result. We agree. ,It is a well-established canon of statutory . interpretation that "'identical words used in different parts of the same act are intended to have the same meaning."' United States Nat'l Bank of Or: v. Indep. Ins. Agents of Am:, Inc., 508 U.S. 439/460 (1993) (quoting Commissioner v. Keystone Consol…
69. 88 FR 65888 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCProposed Rules (FR)Proposed Sep 26, 2023
    …the No Surprises Act. U.S.C.-Brookings Schaeffer on Health Policy. https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 127.  United States Census Bureau (March 2020). 2017 SUSB Annual Data Tables by Establishm…
70. REG-118988-22 — Notice of Proposed Rulemaking
    IRCProposed Rules (FR)Proposed Feb 18, 2025related by meaning
    he IRS participated in the development of these regulations. List of Subjects in 26 CFR Part 1 Income taxes, Reporting and recordkeeping requirements. Proposed Amendments to the Regulations Accordingly, the Treasury Department and the IRS propose to amend 26 CFR part 1 as follows: PART 1—INCOME TAXES Paragraph 1. The a…
71. Treas. Reg. § 54.6694-3(a) — Penalty for understatement due to willful, reckless, or intentional conduct.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) In general. A person who is a tax return preparer of any return or claim for refund of excise tax under chapter 43 of subtitle D of the Internal Revenue Code (Code) shall be subject to penalties under section 6694(b) of the Code in the manner stated in § 1.6694-3 of this chapter.
72. T.C. Memo. 2014-27 — Boyd J. Black & Janice C. Black v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    includible in income under section 61(a)(12) and subject to tax. However, this issue is moot because petitioners' debts were not discharged but rather extinguished, and thus petitioners' income was not from discharge of indebtedness. III. Accuracy-Related Penalty Section 6662(a) imposes an accuracy-related penalty equa…
73. 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
    —Shared Responsibility for Employers Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b). (136) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discha…