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78 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 141 T.C. No. 19 — Andrew Wayne Roberts v. Commissioner
    IRCCourt RulingsDec 30, 2013related by meaning
    . - 26 - return or in a statement attached to the return and there is a reasonable basis for the taxpayer's treatment of the item. Sec. 6662(d)(2)(B). The Commissioner bears the initial burden of production with respect to the taxpayer's liability for the section 6662 penalty. Sec. 7491(c). At trial the Commissioner mu…
  2. PBGC Op. Ltr. 1994-8 — Withdrawal liability
    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…
  3. 29 C.F.R. § 2570.9 — Decision of the administrative law judge.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.57 of this title.
  4. 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…
  5. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of T.C. Memo. 1996-265 UNITED STATES TAX COURT HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respond…
  6. 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 …
  7. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002related by meaning
    ot entitled to IRA contribution deductions because they did not substantiate their IRA deductions. Finally, respondent determined that petitioners are liable for an accuracy-related penalty due to a substantial understatement of income tax. Discussion In general, the determinations of the Commissioner in a notice of de…
  8. 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…
  9. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    re to pay his 2004 taxes; and (4) whether the Court should impose a penalty under section 6673 for petitioner's advancement of frivolous or groundless arguments in proceedings instituted primarily for protest or delay. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of the par…
  10. T.C. Memo. 1998-321 — Robert J. Hoaglund v. Commissioner
    IRCCourt RulingsSep 9, 1998related by meaning
    s specified in section 507(a)(2) or 507(a)(8)[ 1 ] of this title, whether or not a clai m for such tax was filed or allowed; * * * - 6 - * * * * * * * (7) to the extent such debt is for a fine, penalty, or forfeiture payable and for the benef it of a governmental unit, and is not compensation for actual pecuniary loss,…
  11. T.C. Summary Opinion 2008-1 — Shawn Timothy Hynes v. Commissioner
    IRCCourt RulingsJan 2, 2008related by meaning
    oner . Sec . 7491(a)(1) ; Rule 142(a)(2) . Petitioner did not argue that section 7491 is applicable, and he did not establish that the burden of proof should shift to respondent . Petitioner, therefore, bears the burden of proving that respondent's determination in the notice of deficiency is erroneous . See Rule 142(a…
  12. 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 …
  13. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    ents of section 2039(c)(3). Due to concessions and in order to reflect petitioner’s claim for an overpayment, Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
  14. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    curacy-related penalty on underpayments .” In relevant part, section 6662(a) and (b) provides: (a) Imposition of penalty. — If this section applies to any portion of an underpayment of tax required to be shown on a return, there shall be added to the tax an amount equal to 20 percent of the portion of the underpayment …
  15. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ; Stevens Pass, Inc., 48 T.C. 532, 541 (1967); cf. Westinghouse Broadcasting Co., supra; but see fn. 7, supra. Decision will be entered under Bule 50. Sec. 416 was reenacted without significant change by Pub. L. 85-861, 85th Cong., 2d Sess. (1958), 72 Stat. 1458, and is set forth as follows in 10 U.S.C. sec. 2388: Sec.…
  16. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
  17. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    acted section 7476 to establish a declaratory judgment procedure under which an - 6 - employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept. 93-807, supra at 107, 1974-3 C.B. at 342. Section 7476 provides: SEC. 7476. DECLARATORY JUDGMENTS RELATING TO…
  18. T.C. Memo. 2013-126 — Laura Ung v. Commissioner
    IRCCourt RulingsMay 13, 2013related by meaning
    under the first-time home purchase exception pursuant to section 72(t)(2)(F); 'Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for the taxable year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2Petitioner conce…