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61. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    ayer liable for tax if the taxpayer fails to pay the tax within 10 days after notice and demand for payment. Section 6330(a) provides that no levy may be made on any property or right to property of any person unless the Secretary has notified such person in writing of the right to a hearing before the levy is made. Se…
62. 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…
63. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …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 262.  See Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Cert…
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)(…