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  1. T.C. Memo. 2015-176 — Ronald Craig Fish v. Commissioner
    IRCCourt RulingsSep 10, 2015related by meaning
    m nt of tax attributable to: (1) negligence or disregard of rules and regulations; or (2) a substantial understatement of income tax. Sec. 6662(a) and (b)(1) and (2). Negligence is defined to include any failure to make a reasonable attempt to comply with the Internal Revenue Code. Sec. 6662(c). The statute defines dis…
  2. 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…
  3. T.C. Memo. 2000-250 — Susan Jane Hoyez, C.P.A. v. Commissioner
    IRCCourt RulingsAug 10, 2000related by meaning
    6, 682 (1977); Pawlak v. Commissioner , T.C. Memo. 1995-7. Finally, there is no indication - 8 - 2 Petitioner contends that under IRS Publication 560, Retirement Plans for the Self-Employed, contributions can be retroactively applied to the previous year if the contributions are made by the due date of the employer’s r…
  4. Treas. Reg. § 301.6652-1(f) — Failure to file certain information returns.
    IRCRegulationsDec 19, 2016related by meaning
    (f) (f) Showing of reasonable cause. The amount imposed by subsection (a), (b), or (c) of section 6652 shall not apply with respect to a failure to file a statement within the time prescribed if it is established to the satisfaction of the district director or the director of the Internal Revenue Service Center that su…
  5. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    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…
  6. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    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 …
  7. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    IRCCourt RulingsMar 22, 2007related by meaning
    ddition to tax must be sustained. Section 6673(a)(1) authorizes the Court to require a taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or groundless or the taxpayer has instituted or pursued the proceeding primarily for delay. Respondent has n…
  8. 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…
  9. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    me-generating activities relating to the items of income, he has satisfied that obligation through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation should have been divided between himself and his spouse, there is no basis for making any apportionment. …
  10. 87 FR 52618 — Requirements Related to Surprise Billing
    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…
  11. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    Memo. 1993-61; Ianniello v. Commissioner , 98 T.C. 165, 180 (1992); cf. Helvering v. Mitchell , 303 U.S. 391, 397 (1938) (holding that the addition to tax for fraud is remedial). Courts have considered the cases - 8 - cited by petitioner in the Federal income tax arena and found that these cases did not apply for purpo…
  12. T.C. Memo. 2012-13 — John K. Goyak & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 11, 2012related by meaning
    al authority unde section 6664. See Rule 142(a);.Higbee v. Commissioner, supra at 446-447. Respondent has met the burden of production by showing that petitioners improperly deducted or failed to rëport $1.4 million contributed to the Millennium Plan and used the funds to purchase assets for the primary benefit of Mr. …
  13. 91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information
    PBGCProposed Rules (FR)Proposed Jul 21, 2026related by meaning
    a waiver because it does not wish to penalize filers that take reasonable and defensible (even if ultimately incorrect) legal positions. C. PBGC Delay Under proposed §§ 4071.24 and 4302.24, PBGC generally will waive the portion of a penalty that accrues because of a delay in PBGC's response to a non-frivolous argument …
  14. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    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…
  15. 88 FR 65888 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCProposed Rules (FR)Proposed Sep 26, 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 127.  United States Census Bureau (March 2020). 2017 SUSB Annual Data Tables by Establishm…
  16. 90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements
    PBGCFinal Rules (FR)Aug 15, 2025related by meaning
    in § 4233.3 and include a statement under penalties of perjury that the plan sponsor must submit with the signed and dated application for partition. PBGC is amending paragraph (b) of § 4233.3 to better comply with the affidavit requirements prescribed by the Department of Justice for perjury cases under 28 U.S.C. 174…