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Go to I.R.C. § 7623 (not yet in the library — opens the official source)
59 documents · 0.47sAllIRCERISAPBGCJoint Board
  1. 142 T.C. No. 21 — Whistleblower 11332-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014
    … Whistleblower Office granted the whistleblower a -6discretionary award determination under section 7623(a) and denied the whistleblower's request for an award under section 7623(b). The whistleblower timely filed the petition seeking review of respondent's award determination. Respondent filed a motion to dismiss for …
  2. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026★ strong match
    …eeding” as might frustrate our review . Id. at 726. II. Statutory and Regulatory Background Section 7623(a) authorizes the payment of sums necessary for “detecting underpayments of tax” or “detecting and bringing to trial and punishment persons guilty of violating the internal revenue laws or conniving at the same.” Se…
  3. 144 T.C. No. 15 — Whistleblower 21276-13W v. Commissioner
    IRCCourt RulingsJun 2, 2015★ strong match
    …e and (2) whether that information, disclosure, and/or action satisfies the requirements of section 7623(b). Undisputed facts were revkaled at the partial trial and are set forth infra. I - 5 - Background I. Petitioner Husband Petitioner husband assisted individuals who were engaged in illegal activities. In 2009 he wa…
  4. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017
    …ng and bringing to trial and punishment persons guilty of violating the internal revenue laws. Sec. 7623(a). Congress enacted the Tax Relief and Health Care Act of 2006 (TRHCA), Pub. L. No. 109-432, div. A, sec. 406, 120 Stat. at 2958, to address perceived problems with the discretionary award regime. See Whistleblower…
  5. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014
    and denied the whistleblower's request for an award under section 7623(b). The whistleblower timely filed the petition seeking review of respondent's award determination. Respondent filed a motion to dismiss for lack of jurisdiction on the ground that respondent's award determination is not subject to judicial review.…
  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. 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…
  8. 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…
  9. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    ns were made negligently or intentionally.”) (emphasis added); see Mathews v. Chevron Corp., 362 F.3d 1172, 1183 (9th Cir. 2004). Back to Citation 37.  84 FR 33348, note 303. The Department observes that this requirement is also consistent with, for example, the requirement under section 206 of the Advisers Act, which …
  10. 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…
  11. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ess doctrine, courts may invalidate laws if "'men of common intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor - - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945 F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra addresses tran…
  12. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    ions, this Court concludes that a section 6673 penalty of $500 is appropriate. It is "inappropriate that taxpayers who promptly pay their taxes should have the cost of Government and tax collection improperly increased by citizens apparently unwilling to obey the law or shoulder their assigned share of the Government c…
  13. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
  14. 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…
  15. Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex…
    IRCNoticesNov 13, 2007related by meaning
    g whether an estate making the section 6166 election will be required to provide security. TAX CONVENTIONS Announcement 2007-107 Announcement 2007-107 The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first noti…
  16. 75 FR 42662 — Debt Collection
    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…
  17. 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…
  18. 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
    r tax-favored savings arrangements, contact Cathy Pastor at (202) 622-6090 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Paperwork Reduction Act The collection of information contained in these final regulations has been reviewed and approved by the Office of Management and Budget in accordance with the Paperwork…
  19. T.C. Memo. 2005-67 — Laura D. Seidel v. Commissioner
    IRCCourt RulingsMar 31, 2005related by meaning
    cted to unnecessary examination or investigations, and only one inspection of a taxpayer’s books of account shall be made for each taxable year unless the taxpayer requests otherwise or unless the Secretary, after investigation, notifies the taxpayer in writing that an additional inspection is necessary. This Court sta…
  20. 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…