PBGCPBGC Opinion LettersSep 30, 1994
…( 4)( B)>
421 9 N otice & Co llection o f W ithdraw al Liab ility
422 1 Reso lution of Disputes
>29 USC 1461 n ote >
OP INI ON :
I
wri te i n res ponse t o your reque st for the opini on
of the Pension Benefit Guaranty Corporation ("PBG C").
Your
fir st r equest c oncerns a par ticu lar
applicat ion of t he princ iples…
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).
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2.
31 U.S.C. 5311.
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3.
31 U.S.C. 5318.
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4. Treasury Order 180-01 (Jul. 1, 2014).
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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 …
75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient… IRCFinal Rules (FR)Jul 23, 2010
…ing Department of Labor claims procedure regulation. That is, the Department of Labor interprets 29 USC 1133 and the DOL claims procedure regulation as already requiring that plans provide claimants with new or additional evidence or rationales upon request and an opportunity to respond in certain circumstances.
See
Br…
IRCCourt RulingsJan 17, 2024related by meaning
at 568 – 69. Petitioner has not explained why the result should be different here.
Petitioner assert s that the placement of section 4973 in the Code i s “irrelevant,” citing section 7806(b) for the proposition that “[n]o inference, implication, or presumption of legislative construction shall be . . .
made by reason …
75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections IRCFinal Rules (FR)Jun 28, 2010
… read as follows:
Authority:
2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
5. Add § 147.108 to read as follows:
§ 147.108
Prohibition of preexisting condition exclusions.
(a)
No preexisting condition exclusions
—(1)
In general.
A …
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/.
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340.
See,
for example, the proposed 2027 HHS notice of benefit and payment parameters (9…
I.R.C. § 6701(e) — Penalties for aiding and abetting understatement of tax liability IRCCode / StatuteJan 4, 1995related by meaning
(e) (e) Certain actions not treated as aid or assistance For purposes of subsection (a)(1), a person furnishing typing, reproducing, or other mechanical assistance with respect to a document shall not be treated as having aided or assisted in the preparation of such document by reason of such assistance.
85 FR 6046 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Feb 4, 2020related by meaning
te for any affected party, file with PBGC a post-distribution certification (PBGC Form 501), completed in accordance with the instructions thereto; or (2)(i) Within 30 days after the last distribution date for any affected party, certify to PBGC, in the manner prescribed in the instructions to PBGC Form 501, that the p…
IRCCourt RulingsSep 9, 1998related by meaning
s and claims against a
debtor's estate. Sec. 507(a)(8) of the Bankruptcy Code provides
a priority for unsecured claims of governmental units for taxes measured by income or gross receipts within the time periods set
forth therein.
by respondent's motion for the reason explained below. However,
because no justiciable is…
IRCCourt RulingsJan 6, 1997related by meaning
etitioners are liable for an
accuracy-related penalty of $4,870 pursuant to section 6662(a)
for 1991. Section 6662 imposes a 20-percent penalty on any portion of any underpayment that is attributable to any
substantial understatement of income tax. Sec. 6662(a)(2),
- 14 -
(b)(2). Respondent based the determination of t…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
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…
89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction IRCProposed Rules (FR)Proposed Mar 25, 2024related by meaning
request under section 6112(b)(1)(A) of the Code.
II. Disclosure of Reportable Transactions by Material Advisors and Penalties for Failure To Disclose Section 6111(a) provides that each material advisor with respect to any reportable transaction shall make a return setting forth: (1) information identifying and describ…
84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b) IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
Pensions
Railroad retirement
Reporting and recordkeeping requirements
Social security
Unemployment compensation
Proposed Amendments to the Regulations Accordingly, 26 CFR part 31 is proposed to be amended as follows:
PART 31—EMPLOYMENT TAXES AND COLLECTION OF INCOME AT THE SOURCE
Paragraph 1.
The authority citation for…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
e rules regarding other penalties listed in section 6662(b).
See § 6662(c), (e)(1), (f)(1), (g)(1), (j)(1), (k) (each beginning with the phrase “[f]or purposes of this section” and explaining the meaning of terms such as “negligence,”
“substantial valuation misstatement,” and so on).
11
Section 6664(c) is titled “ Reas…
IRCCourt RulingsJan 26, 2006related by meaning
ate are treated as payments not
received as an annuity and are taxable. Sec. 72(e)(2)(A).
There is simply not sufficient information in this record to reach a conclusion whether some portion of the $8,000 payment is
not includable in income. The Court and respondent encouraged
- 10 -
petitioner to provide sufficient in…
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…
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…