IRCCourt RulingsFeb 12, 2014related by meaning
… petitioners' income was not from discharge of
indebtedness.
III. Accuracy-Related Penalty
Section 6662(a) imposes an accuracy-related penalty equal to 20% of the
amount of any underpayment of tax that is attributable to a substantial
understatement of income tax. By definition, an understatement is the excess of
the t…
IRCCourt RulingsAug 6, 1997related by meaning
Motion for a Section 6673 Penalty
Respondent submitted a motion for the imposition of a
penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an
amount not to exceed $25,000 whenever it appears that the
taxpayer's position in a proceeding is frivolous,…
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…
IRCCourt RulingsJun 24, 2003related by meaning
a section 6662 accuracyrelated penalty is due with respect to petitioners' tax return
for 1999.
Section 6662(a) imposes a penalty of 20 percent of the portion of the underpayment attributable to negligence or
disregard of rules or regulations. See sec. 6662(a) and (b)(1).
Negligence is defined as any failure to make a …
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 …
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…
IRCCourt RulingsJan 14, 2013related by meaning
…lated
penalty for the 2002, 2003, 2004, and 2005 tax years.
- 39 -
[*39] Subsection (a) of section 6662 imposes an accuracy-related penalty of 20% of any underpayment that is attributa le to causes specified in subsection (b).
Respondent asserts that one or botli of two causes justify the imposition of the
penalty for …
IRCCourt RulingsJan 12, 1998related by meaning
tely $1,026,855 in U. S.
currency deposited into various bank accounts during the period
January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts
alleging violations of customs reporting requirements.
On January 9, 1992, petitioner entered into a plea a…
IRCCourt RulingsSep 29, 2022related by meaning
at trial that he had filed a return for 2012 showing tax due.
Although his 2013 account transcript r eflects a withholding credit of $320 , petitioner has neither argued nor shown that his 2013 withholding equaled or exceeded the
amount of tax shown on his 2012 return. As for 2014, petitioner’s required annual
payment …
IRCCourt RulingsDec 11, 2003related by meaning
Commissioner to disregard the
deficiency procedures and immediately assess and collect any
unpaid section 6654 addition. Section 6213(a) prohibits the Commissioner from immediately assessing and collecting the
section 6654 addition in a post-notice return situation, however,
because section 6665(b)(2) indisputably make…
IRCCourt RulingsJan 3, 2011related by meaning
…nt year life insurance -protection of $113/136.
VI. - Whether Petitioner Is Liableifor the Sectiona6662 Penalty
Respondent contends thatupetitioner is liable for the s
accuracy-related penalty pursuant rto section 6662 (a) on account
of a substantial understatement of tax, or in the alternative,
on account of negligenc…
IRCCourt RulingsJul 21, 2014related by meaning
account transcript showing that he did not file a 2009 return.
The only evidence that petitioner produced was his own uncorroborated testimony,
- 8 - [*8] which, for the reasons previously stated, we do not find credible. We will
therefore sustain the imposition of the section 6651(a)(1) addition to tax.
B. Section 66…
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…
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…
Joint BoardRegulationsDec 30, 2016related by meaning
(a)(5) (5) Solicitation of employment as prohibited under § 10.30, the use of false or misleading representations with intent to deceive a client or prospective client in order to procure employment, or intimating that the practitioner is able improperly to obtain special consideration or action from the Internal Reven…