IRCCourt RulingsDec 16, 2015
ng the income for 2003 equal to the value of the O'Connor policy for that
year.
Section 6664(c)(1) provides that the penalty shall not be imposed with respect to any portion of an underpayment if a taxpayer shows that there was
reasonable cause for, and that the taxpayer acted in good faith with respect to, that
portio…
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 RulingsNov 28, 2012
or she acted with reásonable cause and in good faith. See sec. 6664(c)(1);
Higbee v. Commission r, .116 T.C. at 447, 448. The decision as to whether a taxpayer acted with re sonable cause and in good faith is made on a case-by-case
basis, taking into account all of the pertinent facts and circumstances. See sec.
1.6664…
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
IRCCourt RulingsDec 2, 2010
…nderpayment and -(2) that the taxpa~yer acted in good faith with
respect to the underpayment. Sec. -6664-(c) (1) Regulations promulgated under section 6664(c) further provide that -the
determination of reasonable cause and good faith "is made o a
case-by-case basis, taking into account all pertinent facts and
circumsta…
IRCCourt RulingsFeb 25, 2010
de~ i by taking int o
account all of the pertinent facts and circumstances . Sec . .
1 .6664-4(b)(1), Income Tax Regs . IThe most important factor i s the extent of the taxpayer's effort to assess his or her proper
tax liability . Id . This factor includes, in some circumstances,
the taxpayer's reasonable and good fait…
IRCCourt RulingsApr 3, 2002related by meaning
…equal to 20 percent of the portion of the
underpayment to which section 6662 applies. Under section
6664(c), however, no penalty shall be imposed under section
6662(a) with respect to any portion of an underpayment if it is
shown that there was a reasonable cause for the portion, and that
the taxpayer acted in good fai…
IRCCourt RulingsMar 19, 2025related by meaning
applies, w e sustain respondent’s determination that petitioner
owes the additional tax under section 72(t)(1) for 2021 .
IV. Section 6662(a) Penalty Section 6662(a) and (b)(2) impose s an accuracy-related penalty
equal to 20% of the portion of an underpayment of tax required to be
shown on a return that is attributab…
Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022 IRCNoticesModified Jan 8, 2024
…dual retirement annuity described in section 408(b).
6 The definition of “State” for purposes of 42 USC 1395x(r)(1) is in 42 USC 410(h), which provides that the term “State” includes the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa.
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…& Dana P. Goldman,
Overpaying for Prescription Drugs: The Copay Clawback,
(2018),
https://schaeffer.usc.edu/research/overpaying-for-prescription-drugs/.)
Back to Citation
183.
Megan Thompson (2018), W
hy a Patient Paid a $285 Copay for a $40 Drug, https://www.pbs.org/newshour/health/why-a-patient-paid-a-285-copa…
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…
IRCCourt RulingsJun 17, 1997related by meaning
ederal income tax. See sec.
6662(b)(2). As relevant herein, section 6662(a) imposes an
accuracy-related penalty equal to 20 percent of an underpayment that is due to a substantial understatement of income tax. In
the case of a corporation, a substantial understatement exists if
its income tax was understated by the gre…
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…
81 FR 19086 — Amendments to the Definition of Broker or Dealer in Securities IRCProposed Rules (FR)Proposed Apr 4, 2016related by meaning
regulations at 31 CFR Chapter X.
See 31 CFR 1010.100(e).
Back to Citation
2.
31 U.S.C. 5311.
Back to Citation
3.
31 U.S.C. 5318.
Back to Citation
4. Treasury Order 180-01 (Jul. 1, 2014).
Back to Citation
5.
31 U.S.C. 5318(g) was added to the BSA by section 1517 of the Annunzio-Wylie Act; it was expanded by section …
Notice 2026-9 — This notice provides guidance relating to amendments under section 501 of the SECURE 2.0 Act of 2022 for individual retirement arrangements and annuities (IRAs… IRCNoticesFeb 9, 2026related by meaning
igibility to represent taxpayers before the IRS in examinations of tax returns the preparer both prepared for the taxpayer and signed as the preparer. Additionally, unenrolled/unlicensed return preparers who participate in the AFSP agree to be subject to the duties and restrictions in Circular 230, including the restri…
Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona… IRCNoticesModified Dec 22, 2008
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4… IRCNoticesObsolete Dec 26, 2007
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
IRCCourt RulingsNov 3, 2008related by meaning
his 2001 Federal income
tax return on March 3, 2004--well beyond .the April 15, 2002,
due date . Moreover, he has not disputed the addition to tax or presented any evidence to suggest that his failure to file timely
was due to reasonable cause . Accordingly, we shall sustain
respondent's imposition of the addition . t…
Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr… IRCAnnouncementsMay 9, 2005
…ALTH PLANS
Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
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…