IRCPrivate Letter RulingsAug 20, 2004
…ccount under chapter 1 in computing taxable income or credits against tax of an
individual.
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose inco me without the approval or consent of any
adverse party is, or, in the discretion of the grantor or a non…
IRCPrivate Letter RulingsJul 13, 2001
…ccount under chapter 1 in computing taxable income or credits against tax of an
individual.
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose income without the approval or consent of any
adverse party is, or, in the discretion of the grantor or a nona…
IRCPrivate Letter RulingsAug 13, 1999
…n into account in computing the
taxable income or credits against the tax of an individual.
Section 677(a) provides that the grantor is treated as the owner of any portion of
a trust whose income without the approval or consent of any adverse party is, or, in the
discretion of the grantor or a nonadverse party, or both…
PLR 202047008 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsNov 20, 2020
…fers to the trust is not treated as an owner of any portion of the trust
under sections 671 through 677 or 679.
Section 1.671 – 2(e)(2)(i) provides that a gratuitous transfer is any trans fer other
than a transfer for fair market value. A transfer of property to a trust may be considered
a gratuitous transfer without r…
IRCPrivate Letter RulingsJul 30, 1999
… that the term "grantor" as used in the regulations under subpart E includes a corporation.
Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner
of any portion of a trust whose income without the approval or consent of any adverse
party is, or, in the discretion of the grantor or a nona…
IRCCourt RulingsFeb 18, 1997related by meaning
ioner's retirement distribution's
being taxed twice. We think petitioners' contention is
meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended
by Congress. E.g., Maass v. Higgins
, 312 U.S. 443, 449 (1941);
United States v. Supplee-Biddle Hardware …
PLR 199925042 — Deduction for Contributions of Employer to an Employee's Trust or Annuity Plan and Compensation Under a Deferred-Payment Plan (Deduct. v. Not Deduct.) IRCPrivate Letter RulingsJun 25, 1999
… account under chapter 1 in computing taxable income or credits against tax of
an individual).
IRC §677(a)(2) provides that the grantor shall be treated as the owner of any
portion of a trust whose income without the approval or consent of any adverse
party is, or, in the discretion of the gr antor or a nonadverse part…
IRCPrivate Letter RulingsMar 26, 1999
… that the term "grantor" as used in the
regulations under subpart E includes a corporation.
Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner
of any portion of a trust whose income without the approval or consent of any adverse
party is, or, in the discretion of the grantor or a nona…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
PLR 200418010 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsApr 30, 2004
…der
chapter 1 in computing the taxable income or credits against the tax of an individual).
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose inco me without the approval or consent of any
adverse party is, or in the discretion of the grantor or a nona…
IRCPrivate Letter RulingsMar 12, 1999
… that the term "grantor" as used in the
regulations under subpart E includes a corporation.
Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner
of any portion of a trust whose income without the approval or consent of any adverse
party is, or, in the discretion of the grantor or a nona…
IRCPrivate Letter RulingsMar 12, 1999
…count
under chapter 1 in computing taxable income or credits against
tax of an individual).
Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of any portion of a trust whose
income without the approval or consent of any adverse party is,
or, in the discretion of the grantor or a nona…
IRCPrivate Letter RulingsFeb 12, 1999
…pter 1 of the Code in computing taxable income
or credits against the tax of an individual.
Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of
any portion of a trust whose income, without the approval or consent of any adverse
party, is or, in the discretion of the grantor or a non…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
IRCPrivate Letter RulingsMar 16, 2012
ection 677(a)(2) provides that the grantor shall be treated as the owner
of any portion of a trust whose income without the approval or consent of any adverse party is, or in the discretion of the grantor or an adverse party or both
may be held or accumulated for future distribution to the grantor.
Section 1.677(a) - 1…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
PLR 200704006 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJan 26, 2007
…der
chapter 1 in computing the taxable income or credits against the tax of an individual).
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose inco me without the approval or consent of any
adverse party is, or in the discretion of t he grantor or an ad…
PLR 200703011 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJan 19, 2007
…der
chapter 1 in computing the taxable income or credits against the tax of an individual).
Section 677(a)(2) of the Code provides that the grantor shall be treated as the
owner of any portion of a trust whose inco me without the approval or consent of any
adverse party is, or in the discretion of t he grantor or an ad…
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
PLR 200518008 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsMay 6, 2005
uting the taxable income or credits against the tax of an individual).
Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of any portion of a trust whose inco me without the approval or consent of any
adverse party is, or in the discretion of t he grantor or an adverse party or both m…