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61. I.R.C. § 6701(c) — Penalties for aiding and abetting understatement of tax liability
    IRCCode / StatuteJan 4, 1995related by meaning
    (c) (c) Activities of subordinates (c)(1) (1) In general For purposes of subsection (a), the term "procures" includes— (c)(1)(A) (A) ordering (or otherwise causing) a subordinate to do an act, and (c)(1)(B) (B) knowing of, and not attempting to prevent, participation by a subordinate in an act. (c)(2) (2) Subordinate F…
62. T.C. Memo. 2009-100 — Peter I. & Daria A. Basalyk v. Commissioner
    IRCCourt RulingsMay 14, 2009
    …aria A . Basalyk docket No . 572-0 7 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec . 6651(a)(1) Sec . 6662(a ) 1999 $24,200 2001 52,467 $4 , 658 .75 $4 , 840 .0 0 12,057 .57 10, 460 .8 0 Peter I . Basalyk docket No . 3712-0 7 Additions to Ta x Year Deficiency Sec . 6651(a)(1) Sec . 6651(a)(2) Sec . 665 4…
63. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    ns were made negligently or intentionally.”) (emphasis added); see Mathews v. Chevron Corp., 362 F.3d 1172, 1183 (9th Cir. 2004). Back to Citation 37.  84 FR 33348, note 303. The Department observes that this requirement is also consistent with, for example, the requirement under section 206 of the Advisers Act, which …
64. T.C. Memo. 2022-101 — William T. Ashford v. Commissioner
    IRCCourt RulingsSep 29, 2022
    …the Tax Court Rules of Practice and Procedure. Served 09/29/22 2 Year Deficiency Additions to Tax § 6651(a)(1) § 6651(a)(2) 2 § 6654(a) 2013 $30,347 $6,756.08 $7,506.75 $538.57 2014 32,142 7,143.98 5,873.94 569.37 The issues for decision are whether petitioner (1) had unreported income as set forth in the notice s of d…