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61. 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 …
62. 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…
63. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    IRCCourt RulingsAug 27, 2018related by meaning
    arguments to justify them. We therefore hold that petitioner - 10 - [*10] is liable for the penalty for an underpayment attributable to a substantial understatement of income tax under section 6662(a) and (b)(2) for each year. V. Section 6673 Sanction Respondent moved that the Court impose sanctions against petitioner…
64. T.C. Summary Opinion 2007-168 — Cheryl Kunsman v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    trates actual knowledge by petitioner of the . IRA distribution, at the time she signed th e 6 The five criteria of sec . 6015(b)(1) are conjunctive . Having concluded that sec . 6015(b)(1)(C) is not satisfied, we need not, and do not, discuss the criteria of the other subsections of sec . 6015(b)(1) . - 11 - return . …
65. 89 FR 23090 — Amendment to Prohibited Transaction Class Exemption 84-14 for Transactions Determined by Independent Qualified Professional Asset Managers (the QPAM Exemption)
    ERISAFinal Rules (FR)Apr 3, 2024
    … Costs Plans Will Suffer 2,288 2,288 Review of Past Exemptions 1,608 1,608 Exemption Application 25,861 25,861 Individual Exemption Notices 2,494 2,494 Total Estimated Annual Cost 6,762,827 758,588 Note: Only quantifiable costs are displayed. Transfers If an asset manager cannot rely on the relief under the QPAM Exempt…
66. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008related by meaning
    ven such regulations is well known. See, e.g., Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837 (1984); Swallows Holdino, Ltd. v. Commissioner, 515 F.3d 162 (3d Cir. 2008), vacating 126 T.C. 96 (2006). The delegation Congress made to the Secretary in section 404(k)(5) (A), however, is particularly …
67. 90 FR 4192 — Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025
    …al Office, 201 Varick Street, Room 746, New York, NY 10014, telephone (212) 607-8600, fax (212) 607-8611; jurisdiction: southeastern New York, northern New Jersey. Philadelphia Regional Office, 1835 Market Street, 21st Floor, Mailstop EBSA/21, Philadelphia, PA 19103, telephone (215) 861-5300, fax (215) 861-5347; jurisd…
68. ERISA § 3002(e) (29 U.S.C. § 1202) — Procedures with respect to continued compliance with Internal Revenue requirements relating to participation, vesting, and funding standards
    ERISACode / StatuteJan 5, 2015related by meaning
    (e) (e) Consultative requirements respecting promulgation of proposed or final regulations The Secretary of the Treasury shall consult with the Pension Benefit Guaranty Corporation with respect to any proposed or final regulation authorized by subpart C of part I of subchapter D of chapter 1 of title 26, or by sections…
69. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    e Tax Court (and the Tax Court shall have jurisdiction) to determine the appropriate relief available to the individual under this section * * * - 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4 This amendment applies "with respect to liability for taxes arising or remaining unpaid on or after …
70. Treas. Reg. § 301.6652-1(f) — Failure to file certain information returns.
    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…