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77 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    …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 340.   See, for example, the proposed 2027 HHS notice of benefit and payment parameters (9…
  2. T.C. Memo. 2007-206 — Alex B. Rhodes, Jr. v. Commissioner
    IRCCourt RulingsJul 30, 2007related by meaning
    yer's position is frivolous or groundless or the taxpayer has instituted or pursued th e proceeding primarily for delay . Respondent has not asked the Court to impose a penalty under section 6673(a) against petitioner . However, the Court may, sua sponte, impose this penalty . Pierson v . Commissioner , 115 T .C . 576,…
  3. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008related by meaning
    ified retirement plan during 2002, before he had attained age 59-1/2 . Thus, even if the additional tax under section 72(t) is a "penalty, addition to tax, or additional amount" within the meaning of section 7491(c), a point we do not decide, there is ample evidence in the record to satisfy any burden of production imp…
  4. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    ce 2002-8 supra,-are unrêasonable or incorrect. Furthermore, on a motion f r summary judgm t thàt is prð];>erly'm de and supported, the o poeing party must 9et forth specific facts showing that there is a genuine issue fo trial. Rule 121(d) . Petitioner does not allege thathe has any evidence that wo ld sat-isfy 'that …
  5. T.C. Memo. 2007-327 — Gregory Eugene Thompson v. Commissioner
    IRCCourt RulingsOct 31, 2007related by meaning
    ner's legal obligations here . See, e .g ., Pessin v . Commissioner , 59 T .C . 473, 489 (1972) ; Rosanova v . Commissioner , T .C . Memo . 1985-306 ; Grant v . Commissioner , T .C . Memo . 1980-242 . -11IV . Section 6673 Penalt y We now consider whether petitioner should be held liable for a penalty under section 6673…
  6. T.C. Summary Opinion 2016-52 — Bruce W. Peterson & Lisa A. Peterson v. Commissioner
    IRCCourt RulingsSep 1, 2016related by meaning
    Penalty Respondent determined an accuracy-related penalty of $5,281 for a substantial understatement of Federal income tax. Section 6662(a) and (b)(2) authorizes a 20% penalty on the portion of an underpayment of income tax attributable to a substantial understatement of income tax. Under section 7491(c), the Commissio…
  7. T.C. Memo. 2008-17 — Herbert & Christine Bangs v. Commissioner
    IRCCourt RulingsJan 31, 2008related by meaning
    er sec . 6662(a) . A - 23 - To reflect the foregoing, Decision will be entered for p etitioners in l ocket No . 4467-06 . Decision w 11 be entered for respondent as t the deficiency and for petitioners as to the accuracyrelated penalty under sectio n 6662(a) in docket No . 7221-06 .
  8. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    IRCCourt RulingsJul 26, 1989related by meaning
    June 19, 1986, the Court of Appeals affirmed our decision sub nom. Dillon v. United States, 792 F.2d 849 (9th Cir. 1986). The parties also stipulated: Petitioners accept the determination of tax contained in the deficiency notice as mathematically correct, except they contend that the tax should be computed by applying…
  9. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    (a) (1) and (b)(2), generating excise taxes for the 11 years in question. 3 Respondent has submitted declara tions under penalties of perjury from two IRS officers, both of whom aver that the IRS did not at any point open an examination of petitioner’s 200 4 Federal income tax return. Although p etitioner initially dis…
  10. 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…
  11. 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…
  12. 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…
  13. 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…
  14. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
  15. I.R.C. § 6652(c)(2)(C) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(2)(C) (C) Split-interest trusts In the case of a trust which is required to file a return under section 6034(a), subparagraphs (A) and (B) of this paragraph shall not apply and paragraph (1) shall apply in the same manner as if such return were required under section 6033, except that— In addition to any penalty im…
  16. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  17. 95 T.C. 364; 95 T.C. No. 26 — Wood v. Commissioner
    IRCCourt RulingsSep 27, 1990related by meaning
    . United States, 872 F.2d 564, 568-570 (3d Cir. 1989). Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…