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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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
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(…
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
…
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…
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 …
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
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…
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 …
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…