IRCPrivate Letter RulingsMar 2, 2001related by meaning
n believes a court would find section 4975 to be punitive in nature
and, therefore, considered a penalty under the Bankruptcy Code. See
, e.g. , In re MMR Holding Corp. , 1998 Bankr. LEXIS 1132 (Bankr. M.D. La. 1998) (for purposes
of I.R.C. § 6601, section 4975(a) is a penalty because its aim is to punish wrongful
cond…
IRCCourt RulingsAug 28, 2014
…SUMMARY OPINION
GUY, Special Trial Judge: This case was heard pursuant to the provisions
of section 7463 of the Internal Revenue Code in effect when the petition was
filed.' Pursuant to section 7463(b), the decision to be entered is not reviewable by
¹Unless otherwise indicated, section references are to the Internal R…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
ns
were made negligently or intentionally.”) (emphasis added);
see Mathews
v.
Chevron Corp.,
362 F.3d 1172, 1183 (9th Cir. 2004).
Back to Citation
37. 84 FR 33348, note 303. The Department observes that this requirement is also consistent with, for example, the requirement under section 206 of the Advisers Act, which …
IRCCourt RulingsFeb 24, 2011
…r respondent.
ARMEN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7463 of the Internal Revenue Code in
effect when the petition was filed.1 Pursuant to section
7463 (b) , the decision to be entered is not reviewable by any
Unless otherwise indicated, all subsequent section
references a…
IRCCourt RulingsSep 28, 2011
…ondent. .
DAWSON, Judge: The petition' in this case was filed pursuant
to the provisions of section 7463.1 Pursuant to section 7463(b),.
the decision to be entered is not reviewable by any other court,
and this opinion 'shall not be treated as precedent for any other
1Unless otherwise indicated, all section references …
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…
IRCCourt RulingsJun 25, 2012
…PINION
MARVEL, Judge: The petition in this case was filed pursuant to the . .
provisions of section 7463.1 Pursuant to section 7463(b), the decision to be
'Unless otherwise indicated, section references are to the Internal Revenue
Code in effect when petitioner filed her petition or incurred her administrative and
liti…
Joint BoardRegulationsDec 30, 2016related by meaning
(d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved.
(d)(4)(iv) (iv) Public i…
IRCCourt RulingsDec 8, 2010
…everdon, for respondent.
THORNTON, Judge: This case was heard pursuant to the
provisions of section 7463 of the Internal Revenue Code in effect
at the time the petition was filed. Pursuant to section 7463 (b) ,
the decision to be entered is not reviewable by any other court,
and this opinion shall not be treated as pre…
Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions IRCNoticesAug 24, 2026related by meaning
dual, (3) accepts Saver’s Match contributions, and (4) is designated by the eligible individual, in such form and manner as the Secretary may provide. Section 6433(f)(1) provides that the term “modified adjusted gross income” (MAGI) means adjusted gross income for a taxable year determined without regard to sections 91…
IRCCourt RulingsDec 15, 2009
…spondent .
ARMEN, Special Trial Judge :- This case was heard pursuant to
the provisions .of section 7463 of the Internal Revenue Code in
effect when the petition was filed
.' Pursuant to section
7463(b), the decision to be entered is not reviewable by an y
1 Unless otherwise indicated, all subsequent section
references…
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…
IRCCourt RulingsAug 25, 2009
…respondent .
ARMEN, Special Trial Judge
: This Lase was heard pursuant to
the provisions of section 7463 of the I~'ternal Revenue Code i
n
effect when the petition was filed .' Pu rsuant to sectio n
7463(b), the decision to be entered is rot reviewable by an
y
' Unless otherwise indicated, all 'subsequent section
refer…
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 .
IRCCourt RulingsApr 13, 2010
…spondent .
ARMEN, Special Trial .Judcge
: This case was heard pursuant to
the provisions of section 7463 of the Internal Revenue Code in
effect when the petition was filed
.' Pursuant to section
7463(b), the decision to be entered is not reviewable by an y
1 Unless otherwise indicated, all subsequent section
references…
IRCCourt RulingsSep 10, 2015related by meaning
n October 13, 2011, petitioner's wife sent a final letter to Settlement
Officer Owyhng informing him that petitioner had received his October 6, 2011, letter, and that petitioner had requested an extension of time on September 26,
-7-
[*7] 2011. The letter also reiterated that petitioner had no access to a computer
and…
IRCCourt RulingsSep 3, 2009
…t .
PANUTHOS, Chief Special Trial Judge : This case was heard
pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect when the petition was filed .' Pursuant to
section 7463(b) ; the decision to be entered is not reviewable b y
' Unless otherwise indicated, all section references are'to
the In…
IRCCourt RulingsFeb 10, 2009
…t .
PANUTHOS, Chief Special Trial Judge : This case was heard
pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect when the petition was filed
.1 Pursuant to
section 7463(b), the decision to be entered is not reviewable b
y
1 Unless otherwise indicated, all section references are to
the Int…
IRCCourt RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…
IRCCourt RulingsJul 21, 2008
…respondent .
ARMEN, Special Trial Judge : This case was heard pursuant to
the provisions of section 7463 of the Internal Revenue Code in
effect when the petition was filed .' Pursuant to section
7463(b), the decision to be entered is not reviewable by an y
1
Unless otherwise indicated, all subsequent section
references…