Search the Pension Law Library

61. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    ion 6662(a) and (b) (2). Generally, section 6662(a) and (b) (1) authorizes the Commissioner to impose a 20-percent penalty on the portion of an - 72 - underpayment of income tax attributable to negligence or disregard of rules or regulations. The term "negligence" includes any failure to make.a reasonable attempt to co…
62. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024related by meaning
    icipation. Id. Thus, even though the withdrawal from the taxpayer’s Keogh account was involuntary and the funds were paid directly to the USA pursuant to the Commissioner’s levy, the taxpayer was deemed to constructively receive the funds under section 72(m)(4)(A). 4 In Murillo , 75 T.C.M. (CCH) at 1564, the taxpayer p…
63. I.R.C. § 6057(h) — Annual registration, etc.
    IRCCode / StatuteJan 6, 2025related by meaning
    (h) (h) Cross references For provisions relating to penalties for failure to register or furnish statements required by this section, see section 6652(d) and section 6690. For coordination between Department of the Treasury and the Department of Labor with regard to administration of this section, see section 3004 of t…
64. Treas. Reg. § 54.4980H-6(b) — Administration and procedure.
    IRCRegulationsDec 30, 2016related by meaning
    (b) (b) Effective/applicability date. This section is applicable for periods after December 31, 2014.
65. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014related by meaning
    her traditional IRA, a qualified retirement plan for purposes of section 72(t). S_ee sec. 4974(c)(4). Petitioner wife had not attained age 59½ at the time of the July 31, 2008, distribution. Petitioner wife has not shown that she qualifies for any of the other exemptions in section 72(t)(2). See Phillips v. Commission…
66. REG-129709-03 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409…
    IRCProposed Rules (FR)Proposed Jan 18, 2005related by meaning
    tlines of oral comments to be discussed) at the public hearing scheduled for April 20, 2005, at 10 a.m. must be received by March 30, 2005. ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-129709-03), room 5203, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand del…
67. 87 FR 52618 — Requirements Related to Surprise Billing
    IRCFinal Rules (FR)Aug 26, 2022
    …s Act.” U.S.C.-Brookings Schaeffer on Health Policy. (March 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 114.  2 U.S.C. 1501 et seq. (1995). Back to Citation 115.  See House Conf. Rep. No. 104-73…
68. Treas. Reg. § 1.408-1(c)(2)(ii) — General rules.
    IRCRegulationsMay 18, 2016related by meaning
    (c)(2)(ii) (ii) If the trust with which the individual engages in any transaction described in subdivision (i) of this subparagraph is established by an employer or employee association under section 408(c), only the employee who engages in the prohibited transaction is subject to disqualification of his separate accou…
69. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021related by meaning
    notice that a provider, facility, or provider of air ambulance services has initiated the Federal IDR process, upon sending or receiving such notice. (2) The Director will coordinate with the Departments in resolving matters under 26 CFR 54.9816-8T(c)(4)(vii)(A)( 1), 29 CFR 2590.716-8(c)(4)(vii)(A)( 1), or 45 CFR 149.…
70. 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)(…
71. 95 T.C. 364; 95 T.C. No. 26 — Wood v. Commissioner
    IRCCourt RulingsSep 27, 1990related by meaning
    . United States, 872 F.2d 564, 568-570 (3d Cir. 1989). Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
72. PLR 200737046 — Tax on Prohibited Transactions
    IRCPrivate Letter RulingsSep 14, 2007related by meaning
    , , , , , , , , , , , , , , , , , ,
73. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
74. 87 FR 80042 — Exception for Interests Held by Foreign Pension Funds
    IRCFinal Rules (FR)Dec 29, 2022related by meaning
    ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development. ( printed page 80055) List of Subjects in 26 CFR Part 1 Income taxes Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, 26 CFR part 1 is amended a…