IRCCourt RulingsJan 12, 1998related by meaning
Memo. 1993-61; Ianniello
v. Commissioner
, 98 T.C. 165, 180 (1992); cf. Helvering v.
Mitchell
, 303 U.S. 391, 397 (1938) (holding that the addition to tax for fraud is remedial). Courts have considered the cases
- 8 -
cited by petitioner in the Federal income tax arena and found
that these cases did not apply for purpo…
Joint BoardRegulationsDec 30, 2016related by meaning
(d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved.
(d)(4)(iv) (iv) Public i…
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…
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…
80 FR 41318 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Jul 14, 2015related by meaning
Affordable Care Act builds upon their respective roles with respect to the market reforms under title I of HIPAA. For a description of the latter,
see Notice of Signing of a Memorandum of Understanding among the Department of the Treasury, the Department of Labor, and the Department of Health and Human Services at 64 F…
IRCCourt RulingsJun 6, 2016related by meaning
racy-related penalty under section
6662(a) and (b)(2) for an underpayment due to a substantial understatement
of income tax for the 2011 taxable year. Section 6662(a) imposes a 20% "accuracy-related penalty" on an
underpayment of tax attributable to any of the causes listed in section 6662(b).
These causes include "[a]…
80 FR 72192 — Final Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, Dependent Coverage, Appeals, and Patient Protec… IRCFinal Rules (FR)Nov 18, 2015
…d Access to Care for Young Adults.
Health Affairs,
32:1 (2013):pp. 165-174.
Back to Citation
137.
Busch, S.
et al.
ACA Dependent Coverage Provision Reduced High Out-Of-Pocket Health Care Spending For Young Adults.
Health Affairs,
33:8 (2014): pp. 1361-1366 and Mulcahy, A.
et al.
Insurance Coverage of Emergency Care fo…
IRCCourt RulingsNov 25, 2008related by meaning
e Tax Court
(and the Tax Court shall have
jurisdiction) to determine the
appropriate relief available to the
individual under this section * * *
- 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4
This amendment applies "with respect to liability for taxes
arising or remaining unpaid on or after …
T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b… IRCTreasury DecisionsDec 7, 2015
…ealth Insurance and Access to Care for Young Adults. Health Affairs, 32:1 (2013):pp. 165–174
[137] Busch, S. et al. ACA Dependent Coverage Provision Reduced High Out-Of-Pocket Health Care Spending For Young Adults. Health Affairs, 33:8 (2014): pp. 1361–1366 and Mulcahy, A. et al. Insurance Coverage of Emergency Care fo…
Rev. Rul. 2004-4 — Employee stock ownership plans; S corporations; listed transactions. A finding of synthetic equity owned by a disqualified person in a nonallocation year of an… IRCRevenue RulingsFeb 9, 2004
…ion’s general tax-exempt status, all items of income, loss, or deduction taken into account under § 1366(a) and any gain or loss on the disposition of the stock in the S corporation are taken into account in computing the unrelated business taxable income of the organization. In 1997, § 512(e) was amended to provide th…
IRCPrivate Letter RulingsSep 14, 2007related by meaning
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
PBGCRegulationsJan 1, 2017
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
IRCCourt RulingsNov 3, 2008related by meaning
his 2001 Federal income
tax return on March 3, 2004--well beyond .the April 15, 2002,
due date . Moreover, he has not disputed the addition to tax or presented any evidence to suggest that his failure to file timely
was due to reasonable cause . Accordingly, we shall sustain
respondent's imposition of the addition . t…
PBGCRegulationsJan 1, 2017
…t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
PBGCFinal Rules (FR)Nov 5, 2010related by meaning
1 CFR 285.13.
(b) This section does not apply to loans provided to multi-employer pension plans pursuant to 29 U.S.C. 1431, 29 CFR 4261.1 and 4281.47. (c) A debtor who has a judgment lien against the debtor's property for a debt to the United States is not eligible to receive grants, loans or funds directly or indirect…
PBGCRegulationsJan 22, 2018
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
curacy-related penalty on
underpayments .” In relevant part, section 6662(a) and (b) provides:
(a) Imposition of penalty. — If this section applies to any portion of an underpayment of tax required to be
shown on a return, there shall be added to the tax an
amount equal to 20 percent of the portion of the
underpayment …
IRCCourt RulingsFeb 18, 1998related by meaning
statutory provisions and the
legislative histories of those provisions, we hold that
petitioner's use of the distributions from his Keogh and IRA's to purchase stock which he then contributed to the Smith Barney IRA
does not constitute a tax-free rollover contribution under
section 402(c) or 408(d)(3), respectively.
3
…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
… a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information.
3
Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here:
https://www.bls.gov/news.release/pdf/jolts.pd…
IRCCourt RulingsAug 1, 1996related by meaning
event the diversion of
retirement savings for nonretirement purposes and to recapture a
measure of the tax benefits provided by the deferral of income tax through retirement plans. At the same time, Congress
recognized that it was appropriate to provide, under limited
circumstances, an exemption from the tax for certai…