Notice 2026-34 — 2026 Cumulative List of Changes in Plan Qualification Requirements for Defined Benefit Qualified Pre-approved Plans IRCNoticesJun 1, 2026
…ther than a capital asset. Section 1.6050K-1(a)(4)(i) refers to a sale or exchange to which section 751(a) applies as a “section 751(a) exchange.” Section 6050K(a) requires a partnership to file a return if there is a section 751(a) exchange of any interest in the partnership during any calendar year. Section 6050K(a) …
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026
…ther than a capital asset. Section 1.6050K-1(a)(4)(i) refers to a sale or exchange to which section 751(a) applies as a “section 751(a) exchange.” Section 6050K(a) requires a partnership to file a return if there is a section 751(a) exchange of any interest in the partnership during any calendar year. Section 6050K(a) …
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…34
4,826,970 504,465,709
735,318
3 Year Average
4,059,610
4,103,368
1.1763434
4,826,970
504,465,709
751,688
Table 52—DOL's and Department of the Treasury's Summary Table
Year
Estimated number of
respondents
Estimated number of
responses
Burden per
response
(hours)
Total annual burden
(hours)
Total
estimated
labor cost
…
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…
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…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…& Dana P. Goldman,
Overpaying for Prescription Drugs: The Copay Clawback,
(2018),
https://schaeffer.usc.edu/research/overpaying-for-prescription-drugs/.)
Back to Citation
183.
Megan Thompson (2018), W
hy a Patient Paid a $285 Copay for a $40 Drug, https://www.pbs.org/newshour/health/why-a-patient-paid-a-285-copa…
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
or lack of jurisdiction.
Appropriate orders will be issued.
Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
IRCCourt RulingsJan 17, 2024related by meaning
…a ruling that section 4973 impo ses a
“ tax , ” not a “penalty” to which the provisions of section 6751 (b) c ould
appl y . We a gree with respondent and w ill accordingly grant his Motion.
Background
The following facts are derived from the parties’ pleadings, M otion papers, and attached Exhibits. They are stated sol…
IRCCourt RulingsJan 2, 2020related by meaning
principles and to deter the waste of judicial resources. See Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwiler v. Commissioner, T.C. Memo. 2016-18, at *10. The Court has provided ample warnings to petitioners of
the potential implications of continuing to assert frivolous and groundless
arguments. For…
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…
IRCCourt RulingsMar 12, 2015related by meaning
Tax, Additional Amounts, and Assessable Penalties".¹°
What these terms have in common is that they refer to amounts that are assessed
8(...continued) 23, 1998, see Internal Revenue Service Restructuring and Reform Act of 1998,
Pub. L. No. 105-206, sec. 3001(c), 112 Stat. at 727, and the taxpayer in that case
anyway bo…
IRCCourt RulingsDec 28, 2000related by meaning
filed a voluntary petition
for reorganization under chapter 11 of the Bankruptcy Code (the
bankruptcy case). In the bankruptcy case, the Commissioner asserted a section 4971 deficiency against the company for
- 4 -
failure to satisfy the minimum funding standard pursuant to
section 412.
In 1994, petitioner was indicte…
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…
34 T.C. 851 — West Virginia Steel Corp. v. Commissioner IRCCourt RulingsAug 15, 1960related by meaning
n this report.
All statutory references herein are to the Internal Revenue Code of 1939, unless otherwise specified.
SEC. 291. FAILURE TO PILE RETÜRN. (a) In ease of any failure to make and file return required by this chapter, -within the time prescribed by law or prescribed by the Commissioner in pursuance of law, un…
Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022 IRCNoticesModified Jan 8, 2024
…dual retirement annuity described in section 408(b).
6 The definition of “State” for purposes of 42 USC 1395x(r)(1) is in 42 USC 410(h), which provides that the term “State” includes the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa.
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…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
…lie, see supra note 3, has not squarely
addressed the test for determining compliance with section 6751(b). The Court will,
therefore, apply its own precedent on this issue. The Court notes, however, that under
either test, respondent’s burden is satisfied.
27
2. Fraud Penalties
Section 6663(a) imposes a penalty equal …
PBGCProposed Rules (FR)Proposed Jul 22, 2010related by meaning
debtor's employing agency or to the Financial Management Service to implement salary offset, unless the employee files a timely request for a hearing; (v) That a final decision on the hearing, if requested, will be issued at the earliest practicable date, but not later than 60 days after the filing of the request for a…
75 FR 8796 — Civil Penalties Under ERISA Section 502(c)(8) ERISAFinal Rules (FR)Feb 26, 2010related by meaning
ch sets forth additional circumstances in which the Service will automatically approve a request to revoke a section 204 election.
Back to Citation
4. An excise tax under Code section 4971(g)(4) generally applies, in addition to any penalty under ERISA section 502(c)(8), in the case of a failure to adopt a rehabilitat…
Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions IRCNoticesAug 24, 2026
…rtain information addressed in this notice will be subject to the Paperwork Reduction Act (PRA), 44 USC 3507. No collection of information will be required until approved by the Office of Management and Budget (OMB) under the PRA.