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81. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    foregoing quoted terms are specially defined and used under the "Public Salary Tax Act of 1939" ; 3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor "taxpayer," nor "non-resident alien," nor any other "legal entity" "made liable for" or "subject to" any "internal reve…
82. Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”…
    IRCRevenue ProceduresOct 15, 2018related by meaning
    addressed pursuant to a VCP submission, the IRS reserves the right to make a referral of the abusive tax avoidance transaction matter for examination. (c) Audit CAP and SCP (for plans Under Examination). For plans Under Examination, if the IRS determines that the plan or Plan Sponsor was, or may have been, a party to a…
83. PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans
    IRCPrivate Letter RulingsAug 8, 2014related by meaning
    TAX EXEMPT AND GOVERNMENT ENTITIES DIVISION DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 MAY 13 2014 Uniform Issue List: 408.03-00, 2501.00-00, 4973.00-00, 4974.00-00 * * * * * * * * * Legend: Taxpayer A = * * * Decedent 8 = * * * Decedent c = * * * Charity D = * * * Trust = * * * Financia…
84. PLR 200109010 — Sale/Exchange
    IRCPrivate Letter RulingsMar 2, 2001related by meaning
    n believes a court would find section 4975 to be punitive in nature and, therefore, considered a penalty under the Bankruptcy Code. See , e.g. , In re MMR Holding Corp. , 1998 Bankr. LEXIS 1132 (Bankr. M.D. La. 1998) (for purposes of I.R.C. § 6601, section 4975(a) is a penalty because its aim is to punish wrongful cond…