IRCCourt RulingsFeb 25, 2016
…e for
any additions to tax.
- 37 -
[*37] petitioner is liable for the addition to tax under section 6651(a)(1) for 2004
and 2005. VI. Section 6651(a)(2) Addition to Tax
Section 6651(a)(2) imposes an addition to tax on taxpayers for their failure
to timely pay the amount of tax shown on a return. A substitute for return…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(5) civil penalty proceedings, this section shall apply in lieu of 29 CFR 18.41.
Joint BoardRegulationsOct 18, 2016related by meaning
The Joint Board reserves the power to issue such special orders as it may deem proper in any case within the purview of this part.
84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019 ERISAFinal Rules (FR)Jan 23, 2019related by meaning
d recordkeeping requirements
29 CFR Part 500
Administrative practice and procedure
Aliens
Housing
Insurance
Intergovernmental relations
Investigations Migrant labor
Motor vehicle safety
Occupational safety and health
Penalties
Reporting and recordkeeping requirements
Wages
Whistleblowing
29 CFR Part 501
Administrative …
IRCCourt RulingsJul 13, 2010
… and
are hereinafter referred to collectively as the instant case .
SERVED JUL 13 2010
2 -
sections 6651(a)(1) and (2) . and 6654(a)2 for their 2000, 2001,
and 2002 tax years in the following amounts :
Harold X . O'Boyl e
Additions to tax under sec .
Year Deficiency 6651(a)(1) 6651(a)(2) 665 4
2000 $23,688 $5,329 .80 $…
90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Aug 15, 2025related by meaning
RT 4065—ANNUAL REPORT
26. The authority citation for part 4065 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1365.
§ 4065.3
[Amended] 27. Amend § 4065.3 by removing “(Approved by the Office of Management and Budget under control number 1212-0026)”.
PART 4203—EXTENSION OF SPECIAL WITHDRAWAL LIABILITY RU…
IRCCourt RulingsNov 21, 2007
… no
medical disability in his presentation of the case to the Court
.
Addition to Tax Under Section 6651(a)(1) Determined With Respect
to Petitioners' 1999 Retur n
The time for filing petitioners' 1999 return was extended to
December 15, 2000 . Petitioners filed their 1999 return on
November 21, 2001, and, thus, they f…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021related by meaning
posed amendments to 45 CFR 150.205(e)(2) would correct a typographical error which incorrectly referenced in 45 CFR 148.120 instead of 45 CFR 148.210. 6. Notice to the State (45 CFR 150.211)
IRCCourt RulingsJan 30, 2007
alternative
minimum tax liability is unnecessary.
VI. Section 6651(a)(1) Addition to Tax
Section 6651(a)(1) imposes an addition to tax for failure to file a return on .the date prescribed (in this case, April 16,
- 33 -
2001), unless the taxpayer can establish that such failure is due
to reasonable cause and not willf…
IRCCourt RulingsSep 24, 2007
…Consequently , the Court sustains respondent's
imposition of an addition to tax pursuant to section 6651 ( a)(1) .
- 11 -
C . Section 6651(a)(2) Addition to Ta x
Section 6651(a)(2) imposes an addition to tax for failure to
pay the amount of tax shown on a return . That addition to tax
applies only when an amount of tax…
ERISARegulationsJan 1, 2017related by meaning
(c)(2)(ii) (ii) Prohibit any person from taking specified actions, or exercising authority or control, concerning funds or property of a MEWA or of any employee benefit plan, regardless of whether such funds or property have been commingled with other funds or property; and,
(c)(2)(iii) (iii) Bar any person either dire…
PBGCRegulationsSep 15, 2025related by meaning
(c) (c) Where to file. See § 4000.4 of this chapter for information on where to file.
IRCCourt RulingsJun 17, 2024
…ursuant to section 6020(b) is treated as the “return” filed by the taxpayer for this purpose. See
§ 6651(g).
On September 12, 2022, the IRS prepared an SFR setting forth
the adjustments discussed above. Respondent has included with his Motion a properly executed Certification establishing that the SFR satisfied the req…
Joint BoardRegulationsOct 18, 2016related by meaning
(c)(2)(iii) (iii) With respect to subsections (d) (2), (3) and (4), (e)(4)(H), and (f)(4), the Joint Board believes that the imposition of these requirements, which presuppose access and provide for amending records, would impair the ability to conduct investigations and would be unnecessary for the same reasons stated…
IRCCourt RulingsApr 5, 2022
…ly if “it is shown that such failure is due to reasonable cause and not due to willful neglect .” § 6651(a)(1). The taxpayer bears the burden of proof on this
point . Higbee v. Commissioner, 116 T.C. 438, 447 (2001). Petitioner did
not allege or prove that he had reasonable cause for failure to file a return for 2013. …
ERISARegulationsApr 20, 2026related by meaning
(a) (a) -(b) [Reserved]
81 FR 8446 — Requirements for Type I and Type III Supporting Organizations IRCProposed Rules (FR)Proposed Feb 19, 2016related by meaning
equired. It has also been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regulations. In connection with the requirements of the Regulatory Flexibility Act (5 U.S.C. chapter 6), it is hereby certified that the collection of information contained in the pr…
IRCCourt RulingsJan 27, 2014
…ains delinquent, up to a maximum addition of
25% for returns more than four months delinquent. Sec. 6651(a)(1). The addition to tax for delinquent payment is calculated as 0.5% of the amount shown as tax on
-15-
[*15] the return but not paid, with an additional 0.5% for each month or fraction
thereof during which the f…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999
… imposed by section 4975(a).
5
D. Whether Petitioners Are Liable for Additions to Tax Under
Section 6651(a)(1)
Disqualified persons liable for the tax under section
4975(a) must file an annual return on Form 5330 for each
prohibited transaction. Sec. 6011; sec. 54.6011-1(b), Pension
Excise Tax Regs. Neither petitioner …