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61. T.C. Memo. 2015-195 — DNA Pro Ventures, Inc. Employee Stock Ownership Plan v. Commissioner
    IRCCourt RulingsOct 5, 2015
    …ion 401(a) requirements, see Martin Fireproofing Profit-Sharing Plan & Tr. v. Commissioner, 92 T.C. 1173 (1989), and (2) a plan fails to follow the terms of the plan document, see Michael C. Hollen, D.D.S., P.C. v. Commissioner, T.C. Memo. 2011-2. In general, a qualification failure pursuant to section 401(a) is a cont…
62. 85 FR 27693 — Effect of Section 67(g) on Trusts and Estates
    IRCProposed Rules (FR)Proposed May 11, 2020related by meaning
    ies). Other personnel from the Treasury Department and the IRS, however, participated in their development. Statement of Availability of IRS Documents The IRS notice cited in this document is published in the Internal Revenue Bulletin and available from the Superintendent of Documents, U.S. Government Publishing Office…
63. I.R.C. § 6701(c) — Penalties for aiding and abetting understatement of tax liability
    IRCCode / StatuteJan 4, 1995related by meaning
    (c) (c) Activities of subordinates (c)(1) (1) In general For purposes of subsection (a), the term "procures" includes— (c)(1)(A) (A) ordering (or otherwise causing) a subordinate to do an act, and (c)(1)(B) (B) knowing of, and not attempting to prevent, participation by a subordinate in an act. (c)(2) (2) Subordinate F…
64. I.R.C. § 6652(c)(4)(B) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(4)(B) (B) Managers The Secretary may make written demand on an organization subject to penalty under subparagraph (A) specifying in such demand a reasonable future date by which the notice shall be submitted for purposes of this subparagraph. If such notice is not submitted on or before such date, there shall be pa…
65. T.C. Memo. 2012-94 — Child Adult Intervention Services, Inc. v. Commissioner
    IRCCourt RulingsMar 28, 2012related by meaning
    ctive for determinations made after October 16, 2006, this Court has jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v. Commissioner, 130 T.C. 44, 48 & n.4 (2008). - 6 - Respondent does not dispute that petit…
66. 81 FR 27011 — Additional Limitation on Suspension of Benefits Applicable to Certain Pension Plans Under the Multiemployer Pension Reform Act of 2014
    IRCFinal Rules (FR)May 5, 2016related by meaning
    uty Commissioner for Services and Enforcement. Approved: April 29, 2016. Mark J. Mazur, Assistant Secretary of the Treasury (Tax Policy). Footnotes 1.  Section 201 of MPRA makes parallel amendments to section 305 of the Employee Retirement Income Security Act of 1974, Public Law 93-406 (88 Stat. 829 (1974)), as amended…
67. T.C. Memo. 2007-306 — David Brian Nolan v. Commissioner
    IRCCourt RulingsOct 9, 2007related by meaning
    ers . In response to our leniency, petitioner once again ignored our Rules and our order . -5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a sanction pursuant to Rule 123(b) . See Stringer v . Commissioner , 84 T .C . 693, 704-705 (1985), affd . withou…
68. ERISA § 802 (29 U.S.C. § 1193a) — Preemption of State anti-garnishment laws
    ERISACode / StatuteJan 6, 2025related by meaning
    Notwithstanding any other provision of law, this part shall supersede any law of a State which would directly or indirectly prohibit or restrict the use of an automatic contribution arrangement, described in section 1193(d)(2) of this title, for a pension-linked emergency savings account. The Secretary may promulgate r…
69. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    er. Mrs. Gebman did not provide any evidence that persuades us that she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file amendment to petition filed August 28, 2019. VI. Section 6662(a) Penalties Section 6662(a) an…
70. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    IRCCourt RulingsMar 22, 2007related by meaning
    ddition to tax must be sustained. Section 6673(a)(1) authorizes the Court to require a taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or groundless or the taxpayer has instituted or pursued the proceeding primarily for delay. Respondent has n…
71. Circular 230 § 10.51(a)(5) — Incompetence and disreputable conduct.
    Joint BoardRegulationsDec 30, 2016related by meaning
    (a)(5) (5) Solicitation of employment as prohibited under § 10.30, the use of false or misleading representations with intent to deceive a client or prospective client in order to procure employment, or intimating that the practitioner is able improperly to obtain special consideration or action from the Internal Reven…
72. Treas. Reg. § 1.411(a)-9 — [Reserved]
    IRCRegulationsMar 14, 2019related by meaning
    [Reserved]