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81. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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 …
82. 29 C.F.R. § 2520.101-2(h) — Filing by multiple employer welfare arrangements and certain other related entities.
    ERISARegulationsOct 1, 2020related by meaning
    (h) (h) Penalties (h)(1) (1) Civil penalties and procedures. For information on civil penalties under section 502(c)(5) of ERISA for persons who fail to file the information required under this section, see § 2560.502c-5 of this chapter. For information relating to administrative hearings and appeals in connection with…
83. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    period starts with the due date of the return. Sec. 6501(b)(1). - 13 - [*13] taxpayer signing the Form 4549 waives the section 6213(a) prohibition on the IRS's assessing a tax deficiency without the mailing of a notice of deficiency. S_e_e sec. 6213(d) (stating that taxpayers may waive restrictions on assessment provi…
84. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    s. 269 1(h)(2)(ii)(A) (2006), a foreign legal restriction will be accounted for in making a section 482 allocation on ly if the restriction applies to controlled persons (which includes related persons) and uncontrolled persons. Therefore, it is evident that the Treasury Department was aware that some foreign legal res…