IRCRegulationsSep 13, 2021
… The total plan payment must be made in accordance with the timing requirement described in section 9817(b)(6), or in cases where the out-of-network rate is determined under a specified State law or All-Payer Model Agreement, such other timeframe as specified by the State law or All-Payer Model Agreement.
T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (… IRCTreasury DecisionsMar 7, 2005related by meaning
Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified.
EXEMPT ORGANIZATIONS
T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
IRCCourt RulingsAug 27, 2018related by meaning
arguments to justify them. We therefore hold that petitioner
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[*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…
I.R.C. § 6701(d) — Penalties for aiding and abetting understatement of tax liability IRCCode / StatuteJan 4, 1995related by meaning
(d) (d) Taxpayer not required to have knowledge Subsection (a) shall apply whether or not the understatement is with the knowledge or consent of the persons authorized or required to present the return, affidavit, claim, or other document.
Notice 2024-1 — This notice provides the indexing factors to be used by group health plans and health insurance issuers to calculate the qualifying payment amount (QPA) for it… IRCNoticesJan 8, 2024
…yment amounts (QPAs) for items and services furnished during 2024 for purposes of sections 9816 and 9817 of the Internal Revenue Code (Code), sections 716 and 717 of the Employee Retirement Income Security Act of 1974 (ERISA), and sections 2799A-1 and 2799A-2 of the Public Health Service Act (PHS Act). These provisions…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…816, ERISA section 716, and PHS Act section 2799A-1.
Back to Citation
49.
Codified in Code section 9817, ERISA section 717, and PHS Act section 2799A-2.
Back to Citation
50.
Codified in Code sections 9816 and 9817, ERISA sections 716 and 717, and PHS Act sections 2799A-1 and 2799A-2.
Back to Citation
51.
U.S. Depart…
IRCCourt RulingsFeb 4, 1998related by meaning
ent under section 6654; and
(4) whether petitioner is liable for a penalty under section
6673. We hold for respondent on all issues. We also hold that petitioner is liable for a penalty under section 6673 and require
him to pay to the United States a penalty of $5,000. Unless
otherwise stated, section references are to…
IRCCourt RulingsMay 6, 2014related by meaning
ars after the last date on
which a petition for review could be filed; but of course, the amount of
the bond cannot exceed twice the deficiency. * * * On August 19, 2010, petitioner appealed the deficiency case to the Court of
Appeals for the Ninth Circuit but did not post a bond pending appeal. On appeal
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[*5] pe…
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 …
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…
IRCCourt RulingsAug 8, 2000related by meaning
respondent determined that all
the IRA distributions from Fidelity for the 1996 taxable year
were includable in gross income and therefore included an additional $6,905 of 1996 IRA distributions from Fidelity in
petitioner’s 1996 gross income.
Tax Court Jurisdiction
First, petitioner contends that the order of Discharg…
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
o people with disabilities. Requests for special assistance during the telephonic hearing must be received by September 20, 2021.
Drafting Information The principal author of these proposed regulations is Casey R. Conrad of the Office of the Associate Chief Counsel (Procedure and Administration). Other personnel from t…
IRCCourt RulingsSep 15, 2005related by meaning
Court, the two cases were
consolidated for hearing on the motions to dismiss. The hearing
was held on November 29, 2004, in San Francisco, California. Discussion
Section 6033(a)(1) requires an organization exempt from
taxation under section 501(a) to file."an annual return, stating
specifically the ite s of gross incom…
IRCCourt RulingsAug 10, 2000related by meaning
6, 682 (1977); Pawlak v.
Commissioner
, T.C. Memo. 1995-7. Finally, there is no indication
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2
Petitioner contends that under IRS Publication 560, Retirement Plans for the Self-Employed, contributions can be
retroactively applied to the previous year if the contributions
are made by the due date of the employer’s r…