IRCRegulationsSep 9, 2016
ct to the facility for the 1985 taxable year, the fund's qualified cost for its 1985 taxable year would be only $10,000. Thus, only $10,000 of the $100,000 facility contribution would be deductible by the employer for its 1985 taxable year (i.e., the taxable year of the employer with or within which the applicable taxa…
T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner IRCCourt RulingsJun 17, 1998related by meaning
988 execution of the annuity
agreement is not credible and should not be accepted by the Court
in light of the convincing other evidence of record. We essentially agree with respondent.
The record reflects that although decedent signed the
annuity agreement in late 1988, she retained title to and was the
owner of the l…
87 FR 26806 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests IRCProposed Rules (FR)Proposed May 5, 2022related by meaning
38 years. Accordingly, the annuity interest must be reformed into an interest payable for a term of 38 years.
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(f) * * *
(4)
Other decedents. The present value of an interest not described in paragraph (f)(2) of this section is to be determined under § 20.2031-7(d) in the case of decedents where the valuation …
IRCCourt RulingsAug 30, 1993
…iver on the basis of temporary substantial business hardship under section 412(d). Petitioner's FYE 1985 Form 5500-C, Return/Report of Employee Benefit Plan, filed on August 23, 1985, contains a schedule of the amounts petitioner contributed to the pension plan during the plan year. On that schedule, petitioner listed …
IRCCourt RulingsAug 22, 1994
…contained in section 512(a)(3) as applicable to VEBA’s under the Deficit Reduction Act of 1984. The 1985 proposal suggested that, under general tax principles, the deduction of advanced funding in 1985 would be allowed if the funding did not create a benefit with a useful life of more than 1 year. The 1985 proposal adv…
IRCCourt RulingsMay 28, 1996
…as soon as
administratively feasible after the termination date,
is not subject to the new survivor annuity requirements
[of sections 401(a)(11) and 417]." [See sec. 1.401(a)-11T, Q&A-10, Temporary Income Tax Regs., 50 Fed. Reg.
29373 (July 19, 1985).]
On September 4, 1985, GCI adopted a resolution terminating
the Plan…
IRCCourt RulingsOct 9, 1997
… time the yearend was changed.
The VEBA Trust's account balance at First Interstate on
November 30, 1985, was $1,835,475. On December 11 and 20, 1985,
petitioner contributed $700,000 and $300,000, respectively, to
the VEBA Trust. On December 27, 1985, petitioner contributed
$36,600,000 to the VEBA Trust. Petitioner cla…
Ann. 2005-29 — This document contains corrections to final regulations (T.D. 9130, 2004-26 I.R.B. 1082) under section 401 of the Code relating to required minimum distributio… IRCAnnouncementsApr 25, 2005related by meaning
nguage “under paragraph (c)(1)”.
5. Section 1.401(a)(9)-6(d) Example 3. (i) of A-13, is amended by adding a new second sentence “E was born in 1935.”. 6. Section 1.401(a)(9)-6(f) Example 8. (ii) of A-14, last sentence of the paragraph the word “be” is removed.
Cynthia E. Grigsby,
Acting Chief, Publications and Regulati…
76 FR 49570 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests IRCFinal Rules (FR)Aug 10, 2011related by meaning
ity factor must be computed that takes into account the projection of the donor's actual life expectancy.
* * * * *
(c)
Effective/applicability dates. Section 25.7520-3(a) is effective as of May 1, 1989. The provisions of paragraph (b) of this section, except
Example 5
in paragraph (b)(2)(v) and paragraph (b)(4), are e…
IRCCourt RulingsMar 15, 2004
…in this case, petitioners resided in Bridgeport,
Connecticut. Petitioners Howard T. Owens, Jr., and Ann E. Owens, husband
and wife, were born on July 20, 1934, and March 29, 1941,
respectively. In 1999, petitioners owned multiple IRA accounts,
including a Fidelity Investments Traditional IRA in the name of
Howard T. Ow…
IRCCourt RulingsJun 11, 1996
regular interest", such interest is transferred
from the Accumulation Fund to the Annuity Savings Fund. Md. Ann.
Code, art. 73B, sec. 14(2)(c) (1988). Benefits, are paid from the Expense Fund. Md. Ann. Code, art.
73B, sec. 14(3) (1988 and Supp. 1991).
The Annuity Savings Fund holds a participant's "accumulated
contribu…
Ann. 2006-45 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba… IRCAnnouncementsJul 31, 2006★ strong match
…notice of approval.
The notification should be addressed to:
Internal Revenue Service
SE:T:EP:RA:T1
Announcement 2006-45
1111 Constitution Ave., NW — PE
Washington, DC 20224
Drafting Information
The principal author of this announcement is Calvin Thompson of the Employee Plans, Tax Exempt and Government Entities Divisi…
IRCCourt RulingsAug 13, 1990
…. (GMG), and were participants in GMG’s qualified profit-sharing plan (the plan). From 1980 through 1985, petitioners borrowed money from the plan (sometimes hereinafter collectively referred to as the plan loans). The plan charged 10-percent interest for plan loans made in 1980 and 1981 and 8-percent interest for plan…
PLR 202052004 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsDec 24, 2020related by meaning
a L. Baxter
Senior Technician Reviewer, Branch 4
(Financial Institutions & Products)
cc: --------------------------------
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Ann. 2007-47 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba… IRCAnnouncementsMay 14, 2007★ strong match
…80201 8/10/1987
31. Brown & Company Securities Corporation 20 Winthrop Square Boston, MA 02110 2/27/1985 32. Bruns, Nordeman, Rea & Co. New York, NY 10/31/1977
33. Burke, Christensen & Lewis Securities, Inc. 120 S. La Salle Street Suite 940 Chicago, IL 60603 3/11/1986
34. Burton J. Vincent, Chesley & Co. 105 West Adams…
PLR 202047008 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsNov 20, 2020related by meaning
Internal Revenue Service Department of the Treasury
Washington, DC 20224
Number: 202047008
Release Date: 11/20/2020
Index Number: 72.00-00
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Ann. 2004-72 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba… IRCAnnouncementsOct 12, 2004★ strong match
… April 22, 1997
95. Hanifen, Imhoff, Inc. 1125 17th Street, Suite 1700 Denver, CO 80202 December 3, 1985 96. Harris Investor Services LLC Harborside Financial Center 501 Plaza II Jersey City, NJ 07311 May 1, 2002
97. Hartford Life Insurance Co. Hartford Plaza Hartford, CT 06106 March 3, 1982
98. Hazlett, Burt & Watson,…
IRCCourt RulingsSep 29, 1992★ strong match
…mended twice.
The enrolled actuary for the plan was John W. Lawrence, Jr. (Lawrence). In making the annual actuarial computations of funding requirements and funding limits for the plan years 1985 through 1988, Lawrence used the following actuarial assumptions:
Plan year ending
12131185 12/31/86 12/31/87 12/31/88
Pre-r…
PLR 202235005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsSep 2, 2022related by meaning
ch 4
Office of Associate Chief Counsel
(Financial Institutions and Products)
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Ann. 2005-59 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba… IRCAnnouncementsSep 12, 2005★ strong match
…notice of approval.
The notification should be addressed to:
Internal Revenue Service
SE:T:EP:RA:T1
Announcement 2005-59
1111 Constitution Ave., NW — PE
Washington, DC 20224
Drafting Information
The principal author of this announcement is Calvin Thompson of the Employee Plans, Tax Exempt and Government Entities Divisi…