IRCCode / StatuteJan 24, 2020related by meaning
(c)(1)(D) (D) Public inspection of applications for exemption and notice of status In the case of a failure to comply with the requirements of section 6104(d) with respect to any exempt status application materials (as defined in such section) or notice materials (as defined in such section) on the date and in the mann…
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
ed § 301.6011-15 would also provide that the Commissioner may grant individual waivers of the requirements of this section in cases of undue hardship. 20. Proposed § 301.6012-2, Required Use of Electronic Form for Income Tax Returns of Certain Political Organizations
Section 2301 of the TFA amended section 6011(e), cha…
IRCCourt RulingsSep 24, 2007★ strong match
…e by
petitioner of the . IRA distribution, at the time she signed th e
6 The five criteria of sec . 6015(b)(1) are conjunctive . Having concluded that sec . 6015(b)(1)(C) is not satisfied, we
need not, and do not, discuss the criteria of the other
subsections of sec . 6015(b)(1) .
- 11 -
return . Sec . 6015 ( c)(3)(C) …
IRCCourt RulingsJun 15, 2009★ strong match
…h taxable year to the
extent such liability is attributable to suc
h
understatement .
- 2 8 Section 6015(b)(3) provides : "For purposes of this subsec
tion, the term `understatement' has the meaning given to such
term by section 6662(d) (2) (A) ." Section 6662(d) (2) (A) provides :
SEC . 6662 . IMPOSITION OF ACCURACY-R…
IRCCourt RulingsAug 16, 2005
…n filer can avoid
such joint and several liability by qualifying for relief
therefrom under section 6015.
6 Section 6015 provides three avenues for obtaining relief to
a taxpayer who has filed a joint return: (1) Section 6015(b)
provides full or apportioned relief with respect to
understatements of tax attributable to …
IRCCourt RulingsNov 25, 2008
…ssioner , 85 T .C . 527, 529 (1985) .
2 In this Court an individual has three ways to request sec .
6015(f) relief . First, when an individual petitions the Court to
redetermine a deficiency, the individual may allege as a n
affirmative defense that he or she is entitled to sec . 6015(f)
relief . Second, the individual…
IRCCourt RulingsAug 16, 2005
e enactment of sec. 6015,
relief from the imposition of joint and several liability for
spouses filing joint returns was available under sec. 6013(e). 119 T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir.
2004).
As a general rule, married taxpayers may elect to file a
joint Federal income tax return. Sec. 6013(a)…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
T.C. Memo. 2019-145 — Jane M. Lassek, Petitioner and Michael E. Smith, Intervenor v. Commissioner IRCCourt RulingsOct 28, 2019
…issioner, 119 T.C. 306, 311 (2002),
a_f[d, 101 F. App'x 34 (6th Cir. 2004). I. Relief Under Section 6015(c) for 2011
One of the above-mentioned limited circumstances is set forth in section
6015(c). Upon the taxpayer's election of its application, section 6015(c) limits a
spouse's liability to the portion of the defici…
T.C. Memo. 2011-253 — George R. Ward, Petitioner and Victoria J. Ward, Intervenor v. Commissioner IRCCourt RulingsOct 31, 2011
returns were filed. Sec.
6015(d) (2), (3) (A); sec. 1.6015-3(d) (4) (ii), Income Tax Regs.
The 10-percent additional tax would have been allocated to George R. Ward, not Victoria J. Ward, if they had filed separate
returns. George R. Ward received the distribution. As the
recipient, he was the taxpayer who would have …
IRCCourt RulingsJan 2, 2020
lly separated or lived apart), the requirements of section 6015(c) are not
satisfied and we must look to subsections (b) and/or (f) in turn. Except as otherwise provided, the requesting spouse bears the burden of proving that he or
- 14 -
[*14] she is entitled to section 6015 relief. Rule 142(a); Alt v. Commissioner, 1…
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
to the transaction on or before the first date on which the transaction is required to be disclosed by the person under section 6011.
Special Analyses It has been determined that this Treasury decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not …
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCFinal Rules (FR)Feb 23, 2023related by meaning
n a trade or business.
* * * * *
(d) * * *
(2) * * *
(ii) Casinos exempt under 31 CFR 1010.970(c).
* * * * *
Par. 10.
Section 1.6050I-1 is amended by: a. Revising paragraphs (a)(3)(ii), (c)(1)(iv), and (d)(2)(i) and (ii).
b. In paragraph (d)(2)(iv), redesignating the example as paragraph (d)(2)(iv)(A).
c. Revising newl…
IRCRegulationsDec 19, 2016related by meaning
(b)(4) (4) Section 6051(d), relating to information returns with respect to payments of wages as defined in section 3401(a), in effect with respect to payments made before 1963, and the regulations under such section, within the time prescribed for filing such statement (determined with regard to any extension of time …
IRCCourt RulingsOct 24, 2007
… taxable years 1998,
1999, and 2000 and assessed based on those returns, but not paid,
only section 6015(f) is applicable. See sec. 6015(b)(1) and
(c)(1); Washington v. Commissioner
, 120 T.C. 137, 146-147 (2003).
Section 6015(f) provides, in pertinent part, that a taxpayer
may be relieved of liability for any unpaid t…
IRCCourt RulingsOct 16, 2008
… of the tax consequences of an item giving rise to a
deficiency to satisfy her burden under section 6015(b)(1)(C) .
See Price v . Commissioner , 887 F .2d 959, 964 (9th Cir . 1989) ;
Hopkins v . Commissioner , 121 T .C . 73, 78 n .ll (2003) . Thus,
petitioner had reason to know of the understatement . She cannot
satisf…
IRCCourt RulingsJul 12, 2012
, and (2) relief is not available under section 6015(b) or (c). The Internal
Revenue Service (IRS) has prescribed guidelines for determining whether a requesting spouse qualifies for relief under section 6015(f). See Rev. Proc. 200361, 2003-2 C.B. 296 (effective for requests for section 6015(f) relief filed during or
a…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
utes] × $63.45 = $793.
Back to Citation
65.
5 U.S.C. 601
et seq.
Back to Citation
66.
5 U.S.C. 601(2), 603(a);
see5 U.S.C. 551.
Back to Citation
67. Public Law 104-4, 109 Stat. 48 (Mar. 22, 1995).
Back to Citation
68.
Reorganization Plan No. 4 of 1978 (5 U.S.C. App. 1 (2018)) generally transferred the authority of …
IRCCourt RulingsDec 29, 2008
…r v . Commissioner , 114 T .C . 276, 282
(2000) ; sec . 1 .6013-4(b), Income Tax Regs .
B . Section 6015(f) Equitable Relie f
Section 6015 provides relief from joint and several
liability in certain circumstances . As relevant here, if the
taxpayer does not qualify for relief under section 6015(b) or
(c), then the taxp…