Web(e) generally, striking par. (2) designation and par. (1) which provided cross reference to section 6621(c)(4) of this title for provision giving Tax Court jurisdiction to determine whether any portion of deficiency is a substantial underpayment attributable to tax motivated transactions. 1988—Subsec. (c). Pub. WebSection 6654(a)(1) of the Internal Revenue Code is modified to refer to the rate determined under Section 19521 in lieu of Section 6621 of the Internal Revenue Code. (c) (1)Section …
Section 19521 - Determination of rate, Cal. Rev. & Tax. Code § …
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Sec. 453A. Special Rules For Nondealers
Web15 Apr 1991 · Similarly, the additional interest imposed on underpayments attributable to tax-motivated transactions pursuant to section 6621(c)(3)(A)(ii) also was warranted. As the Tax Court determined, the language of section 6621 includes losses disallowed by reason of invalid debt. Because HGA's losses arise out of long-term notes that do not represent ... Web2 days ago · Pursuant to 19 U.S.C. 1505 and Treasury Decision 85–93, published in the Federal Register on May 29, 1985 (50 FR 21832), the interest rate paid on applicable overpayments or underpayments of customs duties must be in accordance with the Internal Revenue Code rate established under 26 U.S.C. 6621 and 6622. Section 6621 WebIf any amount of tax imposed by this title (whether required to be shown on a return, or to be paid by stamp or by some other method) is not paid on or before the last date prescribed … marisa from touhou