Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to I.R.C. § 682 (not yet in the library — opens the official source)
76 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2007-168 — Cheryl Kunsman v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    y, she has failed to establish that "she did not know, and had no reason to know, that there was [an] understatement" . Sec . 6015(b) (1) (C) . - 10 - The Court concludes that petitioner has failed to satisfy the requirements of section 6015(b)(1)(C)6 Therefore, petitioner does not qualify for relief from joint and sev…
  2. T.C. Memo. 2016-37 — Syed Navaid v. Commissioner
    IRCCourt RulingsMar 3, 2016related by meaning
    n the return of the relevant facts affecting the item's tax treatment and there is a reasonable basis for the taxpayer's treatment of the item. - 10 - [*10] Here, the understatement of income tax is greater than $5,000. Thus, the understatement is substantial for purposes of the section 6662(a) accuracy-related penalty…
  3. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    004 made an excess contribution of $25,132,892 to his individual retirement account (IRA). Section 4973(a) 1 imposes an excise tax “in an amount equal to 6 percent of the amount of the excess contributions” that a taxpayer makes to an IRA in any given year. This tax continues to apply for future years, until such time …
  4. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    ion 6662(a) and (b) (2). Generally, section 6662(a) and (b) (1) authorizes the Commissioner to impose a 20-percent penalty on the portion of an - 72 - underpayment of income tax attributable to negligence or disregard of rules or regulations. The term "negligence" includes any failure to make.a reasonable attempt to co…
  5. T.C. Memo. 1996-212 — Louis R. & Gregoria S. Gomez v. Commissioner
    IRCCourt RulingsMay 1, 1996related by meaning
    to the retiree over the expected duration of the CSRS annuity. Montgomery v. United States , 18 F.3d 500, 502 (7th Cir. 1994); George v. United States , 30 Fed. Cl. 371, 377 (1994); Shimota v. United States , supra at 522. The distributions that petitioner received from the CSRS are subject to taxation under section 72…
  6. 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…
  7. T.C. Memo. 2008-249 — David A. Hughes v. Commissioner
    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…
  8. 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…
  9. T.C. Memo. 2014-143 — Keith Robertson v. Commissioner
    IRCCourt RulingsJul 21, 2014related by meaning
    Commissioner, T.C. Memo. 2013-67, at *23-*24. The IRS cannot rely solely on account transcripts stating that an SFR was prepared in order to meet this burden of production. Ibid. Respondent failed to meet his burden of production under section 7491(c) with respect to the section 6651(a)(2) addition to tax since respond…
  10. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    IRCCourt RulingsOct 29, 2002related by meaning
    s. 6662(d)(2) (B)(ii), 6664(c)(1); secs. 1.6662-3(c), 1.6664-4(a), Income Tax Regs. - 15 - We consider the facts and circumstances in deciding whether the taxpayer acted with reasonable cause and in good faith. Sec. 6664(c)(1); sec. 1.6664-4(b)(1), Income Tax Regs. We conclude that petitioner acted in good faith and wa…
  11. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010related by meaning
    Court may, require the taxpayer to pay a penalty not in excess of $25,000 whenever it appears to this Court that : (a) The proceedings were instituted or,maintained by the taxpayer primarily for-delay ; '(b) the 2 1 taxpayer's position is frivolous or groundless ; or (c) th e taxpayer unreasonably failed to pursue avai…
  12. 89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAFinal Rules (FR)Jan 24, 2024related by meaning
    nt must promptly notify the Department in writing if it learns that a material fact or representation has been omitted from the exemption application. (b) If, at any time during the pendency of an exemption application, the applicant or any other party in interest who would participate in the exemption transaction beco…
  13. 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. …
  14. T.C. Memo. 2009-133 — Paul Rudnick v. Commissioner
    IRCCourt RulingsJun 9, 2009related by meaning
    oner is liable for the accuracy-related penalty under section 6662 on the ground tha t 'there was a substantial understatement of income tax in 2004 . Section 6662(a) and (!b)(2) authorizes the Commissioner to impose a 20-percent penalty .if there is a substantial understatement of income tax . A substantial understate…
  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. T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner
    IRCCourt RulingsJan 21, 1998related by meaning
    second notice of - 12 - deficiency). Petitioner asserts that the 3-year period of limitations on assessment and collection with respect to 1992 income tax deficiencies (which are joint deficiencies) and for section 4975 excise taxe s for years before 1993 had expired. Petitioner characterizes this assertion as a jurisd…