IRCCourt RulingsSep 1, 2016
…,
the Commissioner bears the burden of production with regard to penalties. Higbee
v. Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner has met the
burden of production, the taxpayer has the burden of proving that the penalties are
9Petitioner's annuity contract was a qualified individual retirement annuity…
T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr… IRCTreasury DecisionsDec 9, 2013related by meaning
of safe harbor matching contributions for plan years beginning on or after January 1, 2015.
EMPLOYMENT TAX
T.D. 9646 T.D. 9646
REG–146620–13T.D. 9646 Temporary and proposed regulations under section 3402(p)(3) relating to voluntary withholding agreements allow the Secretary to issue guidance in the Internal Revenue Bu…
IRCCourt RulingsJan 3, 2017
is
appropriate. See sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446
(2001). Once the Commissioner meets his burden of production, the taxpayer bears the burden of proving, through persuasive evidence, that the
Commissioner's penalty determination is incorrect. See Rule 142(a); Welch v.
Helvering, 290 U.S. 111, …
IRCCourt RulingsDec 11, 1997related by meaning
ng
bank at the end of 1992.
Based on our examination of the entire record before us, we
find that petitioners have failed to show that they acted with reasonable cause and in good faith, or that they otherwise
exercised due care or made a reasonable attempt to comply with
the Code, when they claimed the 1992 and 1993 d…
IRCCourt RulingsAug 10, 2015
…, the Commissioner bears the burden of production with regard to
penalties. Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Once the
Commissioner has met the burden of production, the taxpayer has the burden of
proving that the penalties are inappropriate because of reasonable cause or
substantial authority. See Rule…
IRCCourt RulingsFeb 21, 2012related by meaning
Respondent prepared decisiori.documents reflecting respolident's
concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and .
sanctions against respondent based on "reckless professional behavior."
Petitioner is frustr…
Notice 2024-82 — This notice sets forth the 2024 Required Amendments List (2024 RA List). The 2024 RA List applies to individually designed plans qualified under section 401(a)… IRCNoticesDec 23, 2024
…f 2022 (SECURE 2.0 Act).
3 Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (2019).
4 Pub. L. 116-136, 134 Stat. 281 (2020).
5 Division EE of the Consolidated Appropriations Act, 2021, Pub. L. 116-260, 134 Stat. 1182 (2020).
6 Section G of Notice 2020-68, 2020-38 IRB 567, …
Notice 2022-33 — Notice 2022-33 extends the deadlines for amending a retirement plan or IRA to reflect the provisions of Division O of the Further Consolidated Appropriations A… IRCNoticesAug 22, 2022
…lect certain provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (2019), known as the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), and section 104 of Division M of the Further Consolidated Appropriations Act, 2020, known as the…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
Notice 2021-31 — This notice provides guidance on issues relating to the application of § 9501 of the American Rescue Plan Act of 2021 (the ARP), which provides temporary premi… IRCNoticesJun 7, 2021
…d wages under § 2301 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub. L. 116-136, 134 Stat. 281 (March 27, 2020), as amended by the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act), which was enacted as Division EE of the Consolidated Appropriations Act, 2021, Pub. L. 116-2…
IRCCourt RulingsJun 17, 1997related by meaning
er. Sec. 1.6662-4(d)(3)(iii),
Income Tax Regs. Legal opinions are not authority. The
authorities underlying a legal opinion, however, may give rise to substantial authority for the tax treatment of an item. Id.
We conclude that the corporate petitioners are not liable
for the penalties in dispute. We have agreed with p…
Notice 2020-51 — This notice provides guidance relating to the waiver in 2020 of required minimum distributions (RMDs) from certain retirement plans and IRAs due to the amendme… IRCNoticesJul 13, 2020
… plans under section 2203 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, Pub.L. 116-136, 134 Stat. 281 (2020). In particular, the notice:
permits rollovers of waived required minimum distributions (RMDs) and certain related payments, including an extension of the 60-day rollover period for certain d…
T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b… IRCTreasury DecisionsDec 7, 2015
ethod is $116. The amount that would be paid under Medicare for the emergency service, excluding any copayment or coinsurance for the service, is $80. (ii) Conclusion. In this Example 5, the plan is responsible for paying $92.80, 80% of $116. The median amount among those agreed to for the emergency service is $115 and…