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58 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 76 FR 49570 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests
    IRCFinal Rules (FR)Aug 10, 2011
    …ining the present value of remainder interests in a charitable remainder unitrust as defined in § 1.664-3. (iii) Internal Revenue Service Publication 1459, “Actuarial Valuations Version 3C” (2009). This publication includes tables for computing depreciation adjustment factors. See § 1.170A-12. (d) Effective/applicabili…
  2. 88 FR 37424 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests
    IRCFinal Rules (FR)Jun 7, 2023
    …6(e) Table S (on or after 06/01/23). Cross Reference to Regulation Sections for Purposes of Section 664 Valuation period Interest rate Part 1 section Table Valuation, in general   1.664-4 before 01/01/52 4% 1.664-4A(a) 01/01/52-12/31/70 3.5% 1.664-4A(b) 01/01/71-11/30/83 6% 1.664-4A(c) 12/01/83-04/30/89 10% 1.664-4A(d)…
  3. 87 FR 26806 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests
    IRCProposed Rules (FR)Proposed May 5, 2022
    …e fair market value of a remainder interest in a charitable remainder unitrust (as described in § 1.664-3) for transfers for which the valuation date is on or after [applicability date of the Treasury decision adopting these regulations as final regulations], is its present value determined under paragraph (e) of this …
  4. 89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction
    IRCProposed Rules (FR)Proposed Mar 25, 2024
    uitous transfers described in section 664(d)(1)(C) may be paid to or for the use of any person other than an organization described in section 170(c); (C) Whose remainder interest, following the termination of the payments described in section 664(d)(1)(A), is to be transferred to, or for the use of, an organization de…
  5. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    er 1 as determined under subsection (e) by substituting — (i) in paragraph (1)(A), “200 percent” for “150 percent” . . . . 2. Section 6662: Discussion Section 6662(a) is a generally applicable provision through which all accuracy-related penalties are imposed on underpayments of tax. Section 6662(b) lists the penalizab…
  6. Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c…
    IRCNoticesMay 6, 2024
    … and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
  7. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022
    …ause CRTs are exempt from income tax, appreciated property can be sold by the trust tax free. See § 664(c)(1); Treas. Reg. § 1.664-1(a)(1)(i). Howe ver, notwithstanding a CRT’s tax - exempt status, the income earned by the trust is taxable to its inco me beneficiaries upon distribution. See Alpha I, L.P. v. United Stat…
  8. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    er. Mrs. Gebman did not provide any evidence that persuades us that she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file amendment to petition filed August 28, 2019. VI. Section 6662(a) Penalties Section 6662(a) an…
  9. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    IRCCourt RulingsAug 27, 2018related by meaning
    0 and $5,379, respectively; and (4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014 of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a) penalties in writing by making an entry in the Correspondence Examination Automation Case Support…
  10. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …   See Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​05/​03/​provider-charges-relative-to-medicare-rates-2012-2018/​. Back to Citation 210…
  11. 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…
  12. 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 …
  13. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ed work in her capacity as Yolo's employee or officer. Consistent with our conclusion above, we sustain respondent's disallowance of these deductiòns. IV. Additions to Tax and Penalties A. s Burden of Proof Respondent bears the burden of production with regard to the section 6651(a)(1) and (2) additions to tax and the …
  14. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016related by meaning
    …ased from 20% to 30% of the amount of the understatement if the disclosure requirements of section 6664(d)(2)(A), requiring disclosure in accordance with the regulations under section 6011, are not met. Sec. 6662A(c). Section 6664(d) provides a defense to section 6662A if the taxpayer acted with reasonable cause and in…
  15. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    Commissioner to disregard the deficiency procedures and immediately assess and collect any unpaid section 6654 addition. Section 6213(a) prohibits the Commissioner from immediately assessing and collecting the section 6654 addition in a post-notice return situation, however, because section 6665(b)(2) indisputably make…
  16. 89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAFinal Rules (FR)Jan 24, 2024related by meaning
    bbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds or securities; or (ii) A statement describing the applicable investigation, examination, litigation, or controversy; and (12)(i)(A) Either a statement that, within the last 13 years, the …
  17. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024related by meaning
    is obtained on or before the date the IRS issues a notice of deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 …
  18. 89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
    IRCFinal Rules (FR)Apr 3, 2024
    …hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2020/​08/​04/​fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
  19. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    section 6651(a) (1) and (2). "The sec. 6651(a) (1) addition to tax is reduced by the amount of the sec. 6651(a) (2) addition to tax for any month (or fraction thereof) to which an addition to tax applies under both sec. 6651(a) (1) and (2). See sec. 6651(c) (1). "We acknowledge that petitioner failed to assign any err…
  20. I.R.C. § 6652(c)(1)(D) — Failure to file certain information returns, registration statements, etc.
    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…