IRCCourt RulingsDec 22, 2008related by meaning
to willful neglect . See Higbee
v . Commissioner , supra at 446-447 (stating that the taxpayer
bears the burden of proof regarding reasonable cause) . Accordingly, on this issue we sustain respondent's determination .
V . Section 6673(a)(1 )
Section 6673(a)(1) authorizes this Court to penalize up to
$25,000 a taxpayer …
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 …
IRCCourt RulingsSep 24, 2002related by meaning
titioner is not
liable for the sec. 6662 penalty.
3
S.K. apparently stands for Smoothie King, which we gather
was the trade name of a product.
OPINION DAWSON, Judge
: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to section 7443A(b)(3) and
Rules 180, 181, and 182.
1
The Court agrees with and…
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…
Joint BoardRegulationsDec 30, 2016related by meaning
failure to file annual registration and other notifications by pension plan), 6652(f) (relating to the failure to file information required in connection with certain plans of deferred compensation), 6692 (relating to the failure to file actuarial report), 7805(b) (relating to the extent to which an Internal Revenue Se…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
IRCCourt RulingsDec 28, 2000related by meaning
filed a voluntary petition
for reorganization under chapter 11 of the Bankruptcy Code (the
bankruptcy case). In the bankruptcy case, the Commissioner asserted a section 4971 deficiency against the company for
- 4 -
failure to satisfy the minimum funding standard pursuant to
section 412.
In 1994, petitioner was indicte…
IRCCourt RulingsFeb 28, 2024related by meaning
d a refund may be ordered by
such court of any amount col lected within the period during
which the Secretary is prohibited from collecting by levy or through a proceeding in court under the provisions of [section 6213(a)] .
4. Coordination of Section 6501 and 6213 Rules
Section 6503, titled “ Suspension of running of …
IRCCourt RulingsJan 6, 1997related by meaning
etitioners are liable for an
accuracy-related penalty of $4,870 pursuant to section 6662(a)
for 1991. Section 6662 imposes a 20-percent penalty on any portion of any underpayment that is attributable to any
substantial understatement of income tax. Sec. 6662(a)(2),
- 14 -
(b)(2). Respondent based the determination of t…
110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
acted section
7476 to establish a declaratory judgment procedure under which an
- 6 -
employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept.
93-807, supra
at 107, 1974-3 C.B. at 342. Section 7476 provides:
SEC. 7476. DECLARATORY JUDGMENTS
RELATING TO…
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…
T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner IRCCourt RulingsJan 21, 1998related by meaning
second notice of
- 12 -
deficiency). Petitioner asserts that the 3-year period of
limitations on assessment and collection with respect to 1992 income tax deficiencies (which are joint deficiencies) and for section 4975
excise taxe s for years before 1993 had expired. Petitioner
characterizes this assertion as a jurisd…
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…
IRCCourt RulingsJun 23, 2025related by meaning
one fluent in English knows that the word ‘includes’ cannot be assumed
to mean ‘includes only .’ . . .”) ; Waltne r , 107 T.C.M. (CCH) at 1201 (citing United States v. Lat ham , 754 F.2d 747, 750 (7th Cir. 1985) ) .
In sum, petitioner’s arguments have been rejected by the courts
in hundreds of cases, and we will not di…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016related by meaning
sing Form 8821, Tax Information Authorization. (See Form 8821 and Instructions) See section 10.09 for special rules relating to Anonymous Submissions. .08 Penalty of perjury statement. (1) The Plan Sponsor must sign the penalty of perjury statement on the Form 8950 as part of a VCP submission. In addition, the followin…
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008related by meaning
ven such regulations is well
known. See, e.g., Chevron U.S.A., Inc. v. Natural Res. Def.
Council, Inc., 467 U.S. 837 (1984); Swallows Holdino, Ltd. v. Commissioner, 515 F.3d 162 (3d Cir. 2008), vacating 126 T.C. 96
(2006).
The delegation Congress made to the Secretary in section
404(k)(5) (A), however, is particularly …
IRCCourt RulingsAug 1, 2005related by meaning
his annuity policies. As
stated earlier, section 72(e)(5) applies to the surrender of an
annuity contract. See sec. 72(e)(5)(E). Absent exceptions not applicable in the instant case, the law is well settled that a
distribution upon the complete surrender of an annuity contract
is includable in gross income to the exten…
IRCCourt RulingsDec 30, 2013related by meaning
the amount of tax imposed that is shown on the return, reduced by any
rebate. Sec. 6662(d)(2)(A). The amount of the understatement is reduced by that portion of the understatement that is attributable to (1) the tax treatment of any
item if there is or was substantial authority for such treatment, or (2) any item if
t…