IRCCourt RulingsMar 15, 2011
…his amendment applies to distributions occurring after
Mar. 28, 2005. EGTRRA sec. 657(d), 115 Stat. 137, provides:
"The amendments made by this section shall apply to distributions
made after final regulations implementings subsection (c) (2) (A)
are prescribed." The regulations referenced in EGTRRA sec.
657(c) (2) (A)…
IRCCourt RulingsFeb 9, 2023
…hen Treasury
Decision 8470, 58 Fed. Reg. 5271 (Jan. 2 1, 1993) , redesignate d the 1968
regulations
137
as 26 C.F.R. sec s . 1.482-1A and 2A (1994), effective for tax
years beginning on or before April 21, 1993.
138
The redesignated
regulations were printed in the 1996 edition of the Code of Federal
137
The 1968 regula…
IRCCourt RulingsSep 15, 2005related by meaning
tinued...)
- 5 -
of the Secretary, and in the same manner as taxes. Sec.
6652(c) (4) (A).
Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and
demand, the Secretary can collect the tax by levy upon the
property belonging to the person, subject to …
IRCCourt RulingsJul 5, 2011
137 T.C. No. 2
UNITED STATES TAX COURT
ROBERT K. AND JOAN L. PASCHALL,- Petitioners v.
COMMIS IONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1.0478-08, 25825-08.1 , Filed July 5, 2011.
R determined sec. 4973, I.R.C., excise tax deficiencies
and additions to tax under sec. 6651(a) (1), I.R.C., for Ps'
2002 through 20…
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 RulingsSep 26, 1968
…wald v. Commissioner, 366 F. 2d 538 (C.A. 2, 1966), affirming in part and reversing in part 44 T.C. 137 (1965). In 1953, Mr. Greenwald’s employer sold its entire manufacturing business, and 59 of the 60 employees transferred with the business. Only Mr. Greenwald remained with the employer, which continued as an investm…
IRCCourt RulingsMar 7, 2000related by meaning
994 and 1995 tax
liabilities.
We grant respondent's motion for a penalty under section
6673. Under section 6673, this Court may award a penalty to the United States of up to $25,000 when the proceeding has been
instituted or maintained by the taxpayer primarily for delay or
if the taxpayer's position in such proceeding…
IRCCourt RulingsJun 23, 2025related by meaning
Memo. 2002-18, 83 T.C.M. (CCH) 1107 , 1108– 10 (imposing penalty of
$2,000 under section 6673(a)), af f’ d , 54 F. App ’ x 254 (9th Cir. 2002) ; s ee G reat - West Life Assurance Co. v. United States , 678 F.2d 180, 183
( Ct. Cl. 1982) (“The determination of where income is derived or
‘sourced’ is generally of no mome…
IRCPrivate Letter RulingsSep 14, 2007related by meaning
,
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T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003related by meaning
rders) applies for transfers, distributions, and payments made after December 31, 2001.
Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
T.D. 9332 T.D. 9332 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…
REG-138362-04 — Proposed regulations under section 401 of the Code provide guidance on the use of electronic media to provide certain notices to recipients or to transmit part… IRCProposed Rules (FR)Proposed Aug 15, 2005related by meaning
D FISCAL RESPONSIBILITY ACT OF 1982
Par. 8. The authority citation for part 35 continues to read, in part, as follows:
Authority: 26 U.S.C. 7805 * * * Par. 9. Section 35.3405-1 is amended by:
(1) Revising d-35, A.
(2) Removing d-36, Q&A.
The revision reads as follows:
§35.3405-1 Questions and answers relating to withho…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.57 of this title.
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018related by meaning
18071, 18082, 26 U.S.C. 36B, and 31 U.S.C. 9701); and Public Law 103-141, 107 Stat. 1488 (42 U.S.C. 2000bb-2000bb-4).
List of Subjects
26 CFR Part 54 Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590
Continuation coverage
Disclosure
Employee benefit plans
Grou…
IRCCourt RulingsJun 13, 2017related by meaning
accordingly operates to defer Petersen's deductions for the accrued but
unpaid payroll expenses to the year in which such pay was received by the ESOP participants and includible in their gross income.
II. Penalties
The Code imposes a 20% penalty on the portion of any underpayment of tax
attributable to "[n]egligence o…
ERISARegulationsJan 1, 2017related by meaning
(n) (n) 502(c)(6) civil penalty proceeding means an adjudicatory proceeding relating to the assessment of a civil penalty provided for in section 502(c)(6) of ERISA;
85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020 ERISAFinal Rules (FR)Jan 15, 2020related by meaning
yment of homeworkers without a certificate
214-428
428-1,071
Other violations of statutes, regulations or employer assurances
21-214
214-428
428-1,071 PART 570—CHILD LABOR REGULATIONS, ORDERS AND STATEMENTS OF INTERPRETATION
17. The authority citation for subpart G of part 570 continues to read as follows:
Authority:
5…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place for the public hearing will be published in the Federal Register
.
Drafting Information
The principal authors of these proposed regulations are Joshua Rabon, formerly with the Office of Associate Chief Counsel (Intern…