Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to I.R.C. § 645 (not yet in the library — opens the official source)
77 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2020-152 — Brett John Ball v. Commissioner
    IRCCourt RulingsNov 10, 2020related by meaning
    payer had "substantial authority" or, in the case of items adequately disclosed, a "reasonable basis". Sec. 6662(d)(2)(B). Section 6664(c)(1) provides an exception to the imposition of the section 6662(a) accuracy-related penalty if it is shown that there was reasonable cause for the underpayment and the taxpayer acted…
  2. Treas. Reg. § 54.6695-1(a) — Other assessable penalties with respect to the preparation of tax returns for other persons.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) In general. A person who is a tax return preparer of any return or claim for refund of tax under chapter 43 of subtitle D of the Internal Revenue Code (Code) shall be subject to penalties for failure to furnish a copy to the taxpayer under section 6695(a) of the Code, failure to sign the return under section 66…
  3. Treas. Reg. § 54.4975-7(a) — Other statutory exemptions.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) [Reserved]
  4. PLR 201017056 — Tax on Prohibited Transactions
    IRCPrivate Letter RulingsApr 30, 2010
    … April 01, 2010 2:59:47 PM To: ------------------ Cc: Subject: RE: ERISA question The pr ovision 29 USC 1104(b) that you are referring to is section 404(b) of ERISA, that provides that no fiduciary may maintain the indicia of ownership of any assets of a plan outside the jurisdiction of the District Courts of the U.S.,…
  5. Treas. Reg. § 54.6081-1(e) — Automatic extension of time for filing returns for certain excise taxes under Chapter 43.
    IRCRegulationsDec 30, 2016related by meaning
    (e) (e) Penalties. See section 6651 for failure to file a pension excise tax return or failure to pay the amount shown as tax on the return.
  6. 78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-…
    IRCFinal Rules (FR)Nov 13, 2013
    …ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended. List of Subjects 26 CFR Part 54 Excise taxes Health care Health insurance Pensions Reporting and recordkeeping requirements 29 CFR Part 2590 Continuation c…
  7. PBGC Op. Ltr. 1994-8 — Withdrawal liability
    PBGCPBGC Opinion LettersSep 30, 1994
    …( 4)( B)> 421 9 N otice & Co llection o f W ithdraw al Liab ility 422 1 Reso lution of Disputes >29 USC 1461 n ote > OP INI ON : I wri te i n res ponse t o your reque st for the opini on of the Pension Benefit Guaranty Corporation ("PBG C"). Your fir st r equest c oncerns a par ticu lar applicat ion of t he princ iples…
  8. 75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient…
    IRCFinal Rules (FR)Jul 23, 2010
    …ing Department of Labor claims procedure regulation. That is, the Department of Labor interprets 29 USC 1133 and the DOL claims procedure regulation as already requiring that plans provide claimants with new or additional evidence or rationales upon request and an opportunity to respond in certain circumstances. See Br…
  9. 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…
  10. 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 …
  11. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006related by meaning
    c Oil Producing Co. v. United States , 35 F. Supp. 766 (Ct. Cl. 1940)). Further, an ov erpayment of tax can exist only if the amount remitted with the request for an extension of time to file exceeds the final tax liability shown on Form 706. Id. Section 7422 authorizes a taxpayer to institute a civil action for refund…
  12. 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…
  13. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    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 …
  14. T.C. Summary Opinion 2017-57 — Gregory J. Gowen v. Commissioner
    IRCCourt RulingsJul 24, 2017related by meaning
    ated penalty. Section 6662(a) and (b)(1) and (2) imposes a 20% accuracyrelated penalty on any portion of an underpayment attributable to negligence or disregard of rules or regulations or a substantial understatement of income tax. An understatement of income tax is substantial for purposes of section 6662(b)(2) if it …
  15. T.C. Summary Opinion 2017-51 — Arthur Dulik, Jr. & Ellen B. Kugler Dulik v. Commissioner
    IRCCourt RulingsJul 13, 2017related by meaning
    missioner, T.C. Memo. 1995-12, 1995 WL 9151, at *5. There is nothing in the record indicating that Mr. Dulik commenced any business activity as a sole proprietor, nor is it clear to what extent, if any, AED conducted business activity after its incorporation. 6Petitioners provided substantiation for legal fees totaling…
  16. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    statutory provisions and the legislative histories of those provisions, we hold that petitioner's use of the distributions from his Keogh and IRA's to purchase stock which he then contributed to the Smith Barney IRA does not constitute a tax-free rollover contribution under section 402(c) or 408(d)(3), respectively. 3 …
  17. 87 FR 43991 — Examination and Copying of PBGC Records
    PBGCFinal Rules (FR)Jul 25, 2022related by meaning
    le under the rules in this subpart, are likely to exceed $250, PBGC may require advance payment of the entire fee or assurance of payment, as follows: (i) Where the requester has a history of prompt payment of fees under this part, PBGC will notify the requester of the likely cost and obtain satisfactory assurance of f…