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61. 85 FR 27693 — Effect of Section 67(g) on Trusts and Estates
    IRCProposed Rules (FR)Proposed May 11, 2020related by meaning
    ies). Other personnel from the Treasury Department and the IRS, however, participated in their development. Statement of Availability of IRS Documents The IRS notice cited in this document is published in the Internal Revenue Bulletin and available from the Superintendent of Documents, U.S. Government Publishing Office…
62. 89 FR 23090 — Amendment to Prohibited Transaction Class Exemption 84-14 for Transactions Determined by Independent Qualified Professional Asset Managers (the QPAM Exemption)
    ERISAFinal Rules (FR)Apr 3, 2024related by meaning
    t any such crimes or a crime in which any of the foregoing crimes is an element; or any crime that is identified or described in ERISA section 411; or (2) is convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of a crime, however denominated by the laws …
63. 131 T.C. No. 15 — Larry G. & Maria A. Walton Mitchell v. Commissioner
    IRCCourt RulingsDec 15, 2008
    …es for the 1977, 1978, and 1979 tax years by using collateral estoppel--and, by that point, section 6673), followed by Jacobs v. Commissioner , T.C. Memo. 1983-490 (applying collateral estoppel yet again on the same issues decided in the preceding cases for 1980, and again imposing damages under section 6673 for abuse …
64. T.C. Memo. 2016-37 — Syed Navaid v. Commissioner
    IRCCourt RulingsMar 3, 2016related by meaning
    , petitioner tried to keep his tax records and IRS paperwork for 10 years. In 2001 petitioner ran a small pharmacy in addition to working at a Federal Government hospital. On April 19, 2001, he was charged, along with two other codefendants, with diversion of pharmaceuticals from the Department of Veterans Affairs, and…
65. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025
    …of up to $25,000” upon a taxpayer who advanc es frivolous arguments for the purpose of delay. See § 6673(a)(1). We declined to impose a penalty at that time, but we warned petitioner that, if he continued to “ maintain a frivolous or groundless position or continue [d] to maintain this proceeding primarily for delay , …
66. I.R.C. § 6701(a) — Penalties for aiding and abetting understatement of tax liability
    IRCCode / StatuteJan 4, 1995related by meaning
    (a) (a) Imposition of penalty Any person— shall pay a penalty with respect to each such document in the amount determined under subsection (b). (a)(1) (1) who aids or assists in, procures, or advises with respect to, the preparation or presentation of any portion of a return, affidavit, claim, or other document, (a)(2)…