75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Jul 6, 2010related by meaning
r tax-favored savings arrangements, contact Cathy Pastor at (202) 622-6090 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act The collection of information contained in these final regulations has been reviewed and approved by the Office of Management and Budget in accordance with the Paperwork…
IRCCourt RulingsNov 23, 2016
…previous year's return exceeds $150,000, a
higher percentage may apply).
¹5Wheeler v. Commissioner, 127 T.C. at 211.
- 10 -
[*10] under section 6654(d)(1)(B).¹6 Accordingly, Mr. Blair is not liable for a
section 6654 addition to tax.
V. Mr. Blair Is Liable for a Section 6673 Penalty.
A section 6673(a)(1) penalty is war…
IRCCourt RulingsJan 22, 2025
…ient evidence that the tax was
shown on a f ederal income tax return and was not paid. See Wheeler,
127 T.C. at 210; Worsham v. Commissioner , T.C. Memo . 2012-2 19 , slip
op. at 21 – 22 , aff’d , 531 F. App ’ x 310 (4th Cir. 2013).
In a case such as this where the taxpayer has not filed a f ederal
income tax return fo…
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…
IRCCourt RulingsJul 21, 2014
…(a)(2) addition to tax, the IRS must introduce into
evidence a tax return. Wheeler v. Commissioner, 127 T.C. 200, 208-211 (2006),
aff'd, 521 F.3d 1289 (10th Cir. 2008). This can be done by introducing a copy of
the SFR into evidence or by stipulation of the parties that the SFR is valid and
meets the requirements of se…
IRCCourt RulingsJul 24, 2006
127 T .C . No . 1
UNITED STATES TAX COUR T
CHARLOTTE AND CHARLES T . GEE, Petitioners v .
COMMISSIONER OF INTERNAL REVENUE, Responden t
Docket No . 8755-05 . Filed July 24, 2006 .
P rolled over a distribution from her deceased
husband's individual retirement account (IRA) into her
separate IRA upon her husband's death …
IRCCourt RulingsNov 10, 2020related by meaning
payer had "substantial authority" or, in the case of items adequately
disclosed, a "reasonable basis". Sec. 6662(d)(2)(B). Section 6664(c)(1) provides an exception to the imposition of the section 6662(a) accuracy-related penalty if it
is shown that there was reasonable cause for the underpayment and the taxpayer
acted…
IRCCourt RulingsSep 13, 2004
T.C. Summary Opinion 2004-127
UNITED STATES TAX COURT
ROWLAND SETYONO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5500-03S. Filed September 13, 2004.
Rowland Setyono, pro se.
John D. Faucher
, for respondent.
DEAN, Special Trial Judge
: This case was heard pursuant to
the provisions of secti…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of the definitions in § 18.2 of this title:
U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner IRCCourt RulingsJun 26, 2018
…pondent incorrectly asserts that petitioner withdrew Exhibits
110-P through 120-P and 123-P through 127-P introduced during the hearing.
Only Exhibits 110-P through 114-P were withdrawn. Respondent used the
remaining exhibits during the hearing despite objecting to their admissibility. The
Court reserved ruling on Exhi…
89 FR 54284 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCFinal Rules (FR)Jun 28, 2024related by meaning
olding period raises serious concerns that the family pass-through entity exception is being used inappropriately to circumvent the Disallowance Rule. The Treasury Department and the IRS disagree that the Treasury Department and the IRS lack authority to promulgate an anti-abuse rule. Section 170(h)(7)(G) is a specific…
IRCCourt RulingsFeb 22, 1989
ickle had made substantially the same statement on the occasion of his introduction of H.R. 4881. 127 Cong. Rec. E 5125-5126 (daily ed. Nov. 4, 1981). Senator Bentsen’s statements on November 17, 1981, in introducing S. 1855, and on December 4, 1981, in a prepared statement presented at a hearing held on various bills,…
IRCCourt RulingsAug 6, 1991related by meaning
erms “lump-sum credit” and “annuity” in 5 U.S.C. sec. 8343(a) for the same reasons so fully articulated in Shimota v. United States, supra at 522-523. We emphasize, as did the Claims Court, that the “lump-sum credit” reference deals with the situation where the recipient gives up his right to any annuity whatsoever in …
IRCCourt RulingsMay 15, 1978
mit the plan’s vesting schedule to remain unchanged. [S. Rept. 93-127, 93d Cong., 1st Sess. 39, reprinted in U.S. Code Cong. & Adm. News 4875 (1974).] Moreover, the elapsed time method is an alternative method which was promulgated by the Secretary of Labor to accommodate employers who objected to the restrictive natur…
ERISACourt RulingsFeb 22, 2000
for all of the
Plan years due, on April 1, 1999. (T 127) He mailed the individual
participation benefit statements for Plan year 1997 about two weeks later, (T 127) which they were able to do as a result of the
computerization work that had been done for the previous Plan
years. (T 128) He did not receive any objectio…
IRCCourt RulingsAug 10, 2000related by meaning
6, 682 (1977); Pawlak v.
Commissioner
, T.C. Memo. 1995-7. Finally, there is no indication
- 8 -
2
Petitioner contends that under IRS Publication 560, Retirement Plans for the Self-Employed, contributions can be
retroactively applied to the previous year if the contributions
are made by the due date of the employer’s r…
IRCCourt RulingsApr 2, 2020
… that she had first requested in the September 2007 IDR. See supra pt.
III.Z, p. 124 (Period 16).
- 127 -
[*127] On December 23, 2010, Goldberg emailed RA Knighton, telling her that he
intended to file a "1203"46 complaint against Buffamonte, who had been RA
Knighton's group manager but (as of December 23, 2010) no lon…
IRCCourt RulingsDec 30, 2013related by meaning
.
- 26 -
return or in a statement attached to the return and there is a reasonable basis for
the taxpayer's treatment of the item. Sec. 6662(d)(2)(B). The Commissioner bears the initial burden of production with respect to the
taxpayer's liability for the section 6662 penalty. Sec. 7491(c). At trial the
Commissioner mu…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…rs on average to prepare and send requested records, resulting in a per request equivalent cost of $127.[180]
The Department expects that such requests would occur rarely. As such, the Department estimates that one request a year would result in an average annual burden of $127.
11. Summary
The paperwork burden estimat…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…