Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2023
… 2022-4?
In general
.01 This revenue procedure is a general update of Rev. Proc. 2022-4, 2022-1 IRB 161, which sets forth general information about the types of advice provided by Employee Plans Rulings and Agreements; general procedures for letter ruling and determination letter requests; specific procedures for deter…
IRCCourt RulingsMar 12, 2015related by meaning
nd.8
SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265
(2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden
of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg
g, Hyd…
T.C. Memo. 2017-77 — Estate of Hung-Liang Lynn Lin, Deceased, Jeffrey S. Lin, Administrator v. Commissioner IRCCourt RulingsMay 8, 2017related by meaning
penalty on an underpayment due to a substantial
understatement of income tax.
Section 6662(a) imposes a 20% accuracy-related penalty on any portion of an underpayment of tax required to be shown on a return if, as provided by section
6662(b)(2), the underpayment is attributable to any substantial understatement of
inco…
T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.… IRCTreasury DecisionsApr 30, 2007
… at age 62 of $180,000 per year. The age-adjusted section 415(b)(1)(A) dollar limit at age 60.5 is $161,769 (the lesser of $167,727 ($180,000* $82,000/$88,000) and $161,769 (the straight life annuity at age 60.5 that is actuarially equivalent to a deferred annuity of $180,000 commencing at age 62, determined using 5 pe…
IRCCourt RulingsJun 6, 2016related by meaning
racy-related penalty under section
6662(a) and (b)(2) for an underpayment due to a substantial understatement
of income tax for the 2011 taxable year. Section 6662(a) imposes a 20% "accuracy-related penalty" on an
underpayment of tax attributable to any of the causes listed in section 6662(b).
These causes include "[a]…
PBGCRegulationsJan 1, 2017
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
IRCCourt RulingsJun 28, 2017related by meaning
he Commissioner bears the burden of production with respect to penalties.
Sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001). Once the burden of production is met, the taxpayer must come forward with evidence
sufficient to show that the penalty does not apply. Higbee v. Commissioner, 116
T.C. at 447. Pe…
PBGCRegulationsJan 1, 2017
…t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.