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62 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003★ strong match
    …’s imposition of a - 22 - 25-percent addition to tax under section 6651(a). B. Respondent’s Section 6653(a)(1) Determination Section 6653(a)(1) imposes an addition to tax equal to 5 percent of the entire underpayment if any portion of such underpayment is due to negligence or intentional disregard of rules or regulatio…
  2. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997
    …Jane E. Prince, docket No. 22467-93 Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661(a) 1987 $76,684 19,360 4,213 1 19,171 1 50 percent of the interest due on the deficiency. Douglas R. Prince, D.D.S., M.S., P.C., docket No. 8457-94 Additions to Tax Taxable Secs. Secs. Ye…
  3. I.R.C. § 6652(c)(2)(C) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(2)(C) (C) Split-interest trusts In the case of a trust which is required to file a return under section 6034(a), subparagraphs (A) and (B) of this paragraph shall not apply and paragraph (1) shall apply in the same manner as if such return were required under section 6033, except that— In addition to any penalty im…
  4. 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…
  5. 89 T.C. 287; 89 T.C. No. 25 — Larotonda v. Commissioner
    IRCCourt RulingsAug 13, 1987
    … Federal income tax for 1981 in the amount of $11,796.28, and additions to tax pursuant to sections 6653(a)(1) and 6653(a)(2) of $598.81 and 50 percent of the interest due on the underpayment attributable to negligence, respectively. The issues for decision are: (1) Whether a payment made from petitioner Jerry Larotond…
  6. 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…
  7. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981
    … and that additions to tax should be imposed under sections 6651(a)(1) (failure to file return) and 6653(a) (negligence) in the amounts of $274.75 and $110.55, respectively. The issues for decision are: (1) Whether petitioners are liable for an income tax deficiency; ,(2) Whether petitioners are liable for an addition …
  8. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    Misconduct under Section III(a)(2) while adding protections to the exemption by conditioning disqualification on determinations in court proceedings. Ineligibility under amended Section III(a)(2) will result from a Financial Institution or an Investment Professional being found in a final judgment or court-approved set…
  9. 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…
  10. T.C. Memo. 1998-47 — William Spencer & Barbara Ruth Bach v. Commissioner
    IRCCourt RulingsFeb 5, 1998
    …ederal income tax and additions to tax as follows: Additions to Tax Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B) Sec. 6661 $308,201 $61,705.20 $146,064.61 50 percent of the $77,038.75 interest due on $308,201 - 2 - 1 Respondent concedes that: (1) $34,574 of losses disallowed in the notice of deficie…
  11. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    Court, the two cases were consolidated for hearing on the motions to dismiss. The hearing was held on November 29, 2004, in San Francisco, California. Discussion Section 6033(a)(1) requires an organization exempt from taxation under section 501(a) to file."an annual return, stating specifically the ite s of gross incom…
  12. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    ies. Subchapter C, consisting solely of section 6751, sets forth “Procedural Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…
  13. 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…
  14. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
  15. 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…
  16. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016related by meaning
    ed for Forms 5329. Petitioner once again does not argue that his - 38 - [*38] failure to timely pay was due to reasonable cause and not due to willful neglect. Accordingly, petitioner is liable for the addition to tax under section 6651(a)(2) for 2004 and 2005. VII. Section 6662A Penalty Section 6662A provides: "If a t…
  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. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    tely $1,026,855 in U. S. currency deposited into various bank accounts during the period January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts alleging violations of customs reporting requirements. On January 9, 1992, petitioner entered into a plea a…
  19. 77 T.C. 1096 — Cobb v. Commissioner
    IRCCourt RulingsNov 12, 1981
    …50.54 for 1975 and $795.58 for 1976. Also, for 1975, he determined an addition to tax under section 6653(a) of the Internal Revenue Code of 1954 of $92.53. After concessions by the petitioners, the issues for decision are: (1) Whether in 1975 the petitioners made a deductible contribution to a validly created individua…
  20. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    … Federal income tax in the amount of $9,554.75 and addition to tax for the negligence penalty (sec. 6653(a), I.R.C. 1954) in the amount of $477.74. “Petitioner” shall hereinafter refer to petitioner Angelo J. Bianchi. The issues for decision are: (1) Whether petitioner’s wholly owned subchapter S corporation, on its in…