IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
IRCCourt RulingsDec 23, 2008
…savento , for respondent .
SWIFT, Judge : This case was heard pursuant to the
provisions of section 7463 of the Internal Revenue Code in effect
when the petition was filed . Pursuant to section 7463(b), the
decision to be entered is not reviewable by any other court, and
this opinion shall not be treated as precedent f…
IRCCourt RulingsMar 19, 2009
…ondent's motion
. Petitioners filed the petition
in this case pursuant to the provisions of section 7463 of the
Internal Revenue Code in effect at the time that petition wa
s
SERVED Mar 19 2009
2 -
filed .' Pursuant to section 7463(b), the decision to be entere d
is'not reviewable by any other court, and this opinion s…
IRCCourt RulingsNov 3, 2008
…e Kosar , fo respondent .
RUWE,' Judge : This case was heard pursuant to the provision s
of section 7463 of the Intertlal .Re'enue Code in effect when th e
petition was filed .' Pursuant to section 7463(b), the decisio n
to be entered is not reviewa)le,by any other court, and thi s
opinion shall not be treated as prece…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
—Shared Responsibility for Employers Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b). (136) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discha…
IRCCourt RulingsJan 2, 2008
…pondent .
GOLDBERG, Special Trial judge : This case was heard pursuant
to the provisions of section 7463 of the Internal Revenue Code in
effect at the time the petition was filed . Pursuant to section
7463(b), the decision to be entered is not reviewable by any
other court, and this opinion shall not be treated as prec…
ERISARegulationsJan 1, 2017related by meaning
(i)(3)(ii) (ii) Upon receipt by the delivery service, if accomplished using a “designated private delivery service” within the meaning of 26 U.S.C. 7502(f);
(i)(3)(iii) (iii) Upon transmittal, if transmitted in a manner specified in the notice of intent to assess a penalty as a method of transmittal to be accorded such…
IRCCourt RulingsNov 1, 2007
…ndent .
GOLDBERG, Special Trial Judge : This matter was heard
pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect at the time the petition was filed .
Pursuant to section 7463(b), the decision to be entered is no t
reviewable by any other court, and this opinion shall not be
treated as pre…
75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Jul 6, 2010related by meaning
) under section 408(q)); and
(D) Roth IRAs under section 408A.
(ii) Arrangements described in section 220(d) (Archer Medical Savings Accounts (MSAs)); (iii) Arrangements described in section 403(b)(7) (custodial accounts treated as annuity contracts);
(iv) Arrangements described in section 530 (Coverdell education savi…
IRCCourt RulingsJul 26, 2007
…y 26, 2007 .
ARMEN, Special Trial Judge : This case was heard pursuant to
the provisions of section 7463 of the Internal Revenue Code in
effect when the petition was filed .' Pursuant to section
7463(b), the decision to be entered is not reviewable by an y
' All subsequent section references are to the Internal
Revenue…
24 T.C. 460 — Northwest Automatic Products Corp. v. United States IRCCourt RulingsJun 23, 1955related by meaning
e, to the extent possible, uncertainty as to timely commencement and as to the beginning of the critical period for timely completion of a proceeding. We have previously considered a like issue involving the necessity of mailing a notice of deficiency by registered mail in order to determine whether a petition therefro…
IRCCourt RulingsMar 12, 2008
…ingras , for respondent .
WHALEN, Judge : This case was heard pursuant to the
provisions of section 7463 of the Internal Revenue Code in effect
when the petition was filed . Pursuant to section 7463(b), the
decision to be entered is not reviewable by any other court ,
and this opinion shall not be treated as precedent …
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 …
IRCCourt RulingsOct 19, 2010related by meaning
re to pay his 2004 taxes; and
(4) whether the Court should impose a penalty under section
6673 for petitioner's advancement of frivolous or groundless arguments in proceedings instituted primarily for protest or
delay.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the par…