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61. Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2005related by meaning
    her § 264(c)(1) applies. (22) Section 269.—Acquisitions Made to Evade or Avoid Income Tax.—Whether an acquisition is within the meaning of § 269. (23) Section 274.—Disallowance of Certain Entertainment, Etc., Expenses.—Whether a taxpayer who is traveling away from home on business may, in lieu of substantiating the act…
62. 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…
63. ERISA § 4068(c) (29 U.S.C. § 1368) — Lien for liability
    PBGCCode / StatuteJan 6, 2017related by meaning
    (c) (c) Priority (c)(1) (1) Except as otherwise provided under this section, the priority of a lien imposed under subsection (a) shall be determined in the same manner as under section 6323 of title 26 (as in effect on April 7, 1986). Such section 6323 shall be applied for purposes of this section by disregarding subse…
64. I.R.C. § 6662(d)(2)(B)(ii)(I) — Imposition of accuracy-related penalty on underpayments
    IRCCode / StatuteJan 5, 2023related by meaning
    (d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and (d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer. (d)(2)(C) (C) Reduction not to apply to tax shelters (d)(…