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88 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
  2. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    …ay could not have delayed payment, and thus could not 64A third party might also pay the balance. - 161 - [*161] have caused "in whole or in part" the accrual of interest. M sec. 6404(e)(1). For this period, Period 22, Goldberg essentially argues that the IRS's delay in processing his Form 843 prevented him from knowin…
  3. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    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…
  4. 29 C.F.R. § 2560.502c-8(g) — Civil penalties under section 502(c)(8).
    ERISARegulationsJan 1, 2017
    …ount described in paragraph (c) of this section. This notice is a “pleading” for purposes of § 2570.161(m) of this chapter. (g)(2) (2) Except as provided in paragraph (h) of this section, a notice issued pursuant to paragraph (g)(1) of this section, indicating the Department's determination to assess a penalty, shall b…
  5. 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…
  6. 100 T.C. 216; 100 T.C. No. 15 — Halliburton Co. v. Commissioner
    IRCCourt RulingsMar 24, 1993
    Kalmbach, Inc. v. Commissioner, 83 T.C. at 160-161; Peter M. Boruta, M.D., P.C. v. Commissioner, T.C. Memo. 1988-172. In Tipton, we stated as follows: We infer * * * a broader ameliorative purpose than simply preventing the reversion of contributions to an owner-employee. We think that Congress in enacting * * * [the p…
  7. T.C. Memo. 2025-1 — Matthew D. Hutcheson & Annette Hutcheson v. Commissioner
    IRCCourt RulingsJan 2, 2025related by meaning
    ively , petitioners are liable for a section 6662 accuracy - related penalty. We hold Mr. Hutcheson is liable for the fraud penalty . FINDINGS OF FACT W hen the Petition was timely filed , Mrs. Hutcheson resided in Idaho , and Mr. Hutcheson was incarcerated in California . 3 Some facts and exhibits have been deemed sti…
  8. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    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…
  9. 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…
  10. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    foregoing quoted terms are specially defined and used under the "Public Salary Tax Act of 1939" ; 3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor "taxpayer," nor "non-resident alien," nor any other "legal entity" "made liable for" or "subject to" any "internal reve…
  11. T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner
    IRCCourt RulingsJan 21, 1998related by meaning
    second notice of - 12 - deficiency). Petitioner asserts that the 3-year period of limitations on assessment and collection with respect to 1992 income tax deficiencies (which are joint deficiencies) and for section 4975 excise taxe s for years before 1993 had expired. Petitioner characterizes this assertion as a jurisd…
  12. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …2715A(b)(2)(i); 2590.715-2715A(b)(2)(i); and 147.210(b)(2)(i) 0938-NEW * 1,959 1,959 933 1,827,094 $161,494,083 $0 $161,494,083 §§ 54.9815-2715A(b)(2)(ii); 2590.715-2715A(b)(2)(ii); and 147.210(b)(2)(ii) 0938-NEW 1,306 77,400 10 19,350 678,411 35,604 714,015
  13. T.C. Memo. 2009-140 — James A. Haigh v. Commissioner
    IRCCourt RulingsJun 15, 2009related by meaning
    (including interest, penalties, and other amounts) for such taxable year to the extent such liability is attributable to suc h understatement . - 2 8 Section 6015(b)(3) provides : "For purposes of this subsec tion, the term `understatement' has the meaning given to such term by section 6662(d) (2) (A) ." Section 6662(…
  14. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ct that a law with a secular purpose may have the effect of making the observance of some religious beliefs more expensive does not render the statute unconstitutional under the First Amendment." Black v. Commissioner , 69 T.C. 505, 510 (1977) (citation omitted). Section 72(m) has the purpose of requiring taxpayers to …
  15. 157 T.C. No. 10 — Andrew McNulty & Donna McNulty v. Commissioner
    IRCCourt RulingsNov 18, 2021related by meaning
    uch before they were placed in the safe. We question whether labeling is sufficient to satisfy the Code’s prohibition against com m ingling or whether storage in a safe satisfies the requirem ent that assets requiring safekeeping be kept in an adequate vault. However, we do not need to resolve this issue as Mrs. McNult…
  16. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005related by meaning
    ted penalty pursuant to section 6662(a) with respect to the underpayment attributable to the unreported 10-percent additional tax under section 72(t). Section 6662(a) imposes a 20-percent penalty on the portion of any underpayment attributable to any of various factors, one of which is negligence or disregard of rules …
  17. 29 C.F.R. § 2570.7 — Scope of discovery.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
  18. 81 FR 21181 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit Plans and Broker-De…
    ERISAFinal Rules (FR)Apr 8, 2016
    …rs. Production and Distribution of Required Disclosures The Department estimates that approximately 161,000 plans and 2,000 managed IRAs and non-ERISA plans have relationships with financial institutions and are likely to engage in transactions covered under this exemption. Of these 161,000 plans and 2,000 managed IRAs…
  19. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026related by meaning
    the average taxpayer, and he relies on that knowledge for a career. And n ot just any career, but one that requires him to examine returns for the 30 same types of tax avoidance he himself engaged in. It is clear that he is liable for the fraud penalty for each year at issue. Although section 6664(c)(1) provides that …
  20. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014related by meaning
    ir return relevant facts concerning the distributions. Accordingly, they fail the first requirement of the section 6662(d)(2)(B)(ii) exception, and we need not analyze whether petitioners had a reasonable basis for their position. Section 6664(c)(1) provides another method by which petitioners may avoid the section 666…