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,…
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…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
—Shared Responsibility for Employers Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b). (136) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discha…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
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…
IRCCourt RulingsAug 8, 2000related by meaning
f sections 6212(a) and 6213(a).
- 5 -
Because this Court is a court of limited jurisdiction,
petitioner’s fraud argument is misplaced. The Court lacks jurisdiction to review or set aside the order of discharge
entered by the bankruptcy court. Therefore, petitioner’s
contention that the bankruptcy discharge is void beca…
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 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 …
IRCCourt RulingsJan 14, 2013related by meaning
elated
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 RulingsApr 2, 2020related by meaning
period starts with the due
date of the return. Sec. 6501(b)(1).
- 13 -
[*13] taxpayer signing the Form 4549 waives the section 6213(a) prohibition on the IRS's assessing a tax deficiency without the mailing of a notice of deficiency.
S_e_e sec. 6213(d) (stating that taxpayers may waive restrictions on assessment
provi…