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72 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner
    IRCCourt RulingsDec 13, 2018related by meaning
    ners are liable under section 6662(a) and (b)(2) for an accuracy-related penalty on an underpayment due to a substantial understatement of income tax. Section 6662(a) imposes a 20% accuracy-related penalty on any portion of an underpayment of tax required to be shown on a return if, as provided by section 6662(b)(2), t…
  2. 75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections
    IRCFinal Rules (FR)Jun 28, 2010
    … read as follows: Authority: 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended. 5. Add § 147.108 to read as follows: § 147.108 Prohibition of preexisting condition exclusions. (a) No preexisting condition exclusions —(1) In general. A …
  3. 89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAFinal Rules (FR)Jan 24, 2024related by meaning
    rimes is an element; or any crime identified in ERISA section 411, regardless of whether the conviction occurred in a U.S. or foreign jurisdiction; 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…
  4. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    …the No Surprises Act. U.S.C.-Brookings Schaeffer on Health Policy. https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 340.   See, for example, the proposed 2027 HHS notice of benefit and payment parameters (9…
  5. 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…
  6. 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)(…
  7. Treas. Reg. § 1.72-13(e) — Special rule for employee contributions recoverable in three years.
    IRCRegulationsJul 26, 2016related by meaning
    (e) (e) Inapplicability of section 72(d) and this section. Section 72(d) and this section do not apply to: (e)(1) (1) Amounts received as proceeds of a life insurance contract to which section 101(a) applies, nor to (e)(2) (2) Amounts paid to a surviving annuitant under a joint and survivor annuity contract to which pa…
  8. 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…
  9. T.C. Memo. 2022-101 — William T. Ashford v. Commissioner
    IRCCourt RulingsSep 29, 2022related by meaning
    ith section 6751(b) (1). That section provides: “ No penalty under this title shall be assessed unless the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the 9 The SFRs comprise Form s 4549, 886– A, and 13496. That combination of documents is sufficient to co…
  10. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    e relaxed transfer pricing rules of section 925(a)(1) and (2) were used instead of the normal section 482 rules, then the lower the profit margin on a particular export transaction, the lower the effective marginal tax rate for that transaction (because as the profit margin decreased, the amount of taxable income assig…
  11. 29 C.F.R. § 4000.28 — [Reserved]
    PBGCRegulationsDec 7, 2023related by meaning
    [Reserved]
  12. PLR 200109010 — Sale/Exchange
    IRCPrivate Letter RulingsMar 2, 2001related by meaning
    n believes a court would find section 4975 to be punitive in nature and, therefore, considered a penalty under the Bankruptcy Code. See , e.g. , In re MMR Holding Corp. , 1998 Bankr. LEXIS 1132 (Bankr. M.D. La. 1998) (for purposes of I.R.C. § 6601, section 4975(a) is a penalty because its aim is to punish wrongful cond…