IRCCourt RulingsDec 11, 2003
…t
Docket No. 16032-95. Filed December 11, 2003.
P has been continuously incarcerated since June 17,
1988. For P’s 1988 taxable year, R (1) determined a tax
deficiency based upon amounts reported on information
returns as having been paid to P during that year, (2)
imposed the 10-percent additional tax under sec. 72(t)(…
T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner IRCCourt RulingsJun 17, 1998★ strong match
s accountant had valued
decedent's annuity pursuant to the pertinent actuarial table (see
Table A in sec. 20.2031-7A(d)(6), Estate Tax Regs.) provided under the regulations in effect in late 1988, then he presumably
would have computed a value for the annuity of at most
$1,305,866.20 ($311,165 multiplied by 4.1967). Th…
IRCCourt RulingsMar 15, 2004★ strong match
…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 RulingsAug 15, 1994
…oration timely filed its Federal income tax return, Form 1120S, for its taxable year ended June 30, 1988, on September 15, 1988. The corporation made the following timely contributions to the trust forming a part of the Resource Systems, Inc. Employees Pension Plan (the plan) for the plan’s year ended June 30, 1988: On…
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.
* * * * *
(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 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…
IRCCourt RulingsJul 15, 1997
x
6651(a)(1)
6653(a)(1)(A)
6653(a)(1)(B)
6661(a)
1987 $7,348-367
1
-
1988 29,345 2,935 1,467-7,336
1
50 percent of the interest due on the deficiency. Unless otherwise indicated, all section and Code references
are to the Internal Revenue Code as in effect for the years in
issue, and all Rule references are to the Tax …
IRCCourt RulingsOct 9, 1997
as in fact only $7,992,215. The
deductible contribution amount for the 1988 plan year was
$13,243,405.
5
During the 1988 year, $4,092,000 was paid for PRMB's. Accordingly, the increase in the required reserve at the
1988 plan yearend is $9,151,405 ($13,243,405 less $4,092,000).
Consequently, the total reserve balance s…
Ann. 2004-58 — Relative value regulations; effective dates; notices; qualified joint and survivor annuities. This announcement postpones, in certain circumstances, the effect… IRCAnnouncementsJul 19, 2004related by meaning
…nefit to be more valuable than the QJSA.
Contact Information For further information regarding this announcement, please contact Diane Bloom at (202) 283-9888, or Linda Marshall at (202) 622-6090. These numbers are not toll-free.
IRCCourt RulingsOct 11, 1995
…employees and teachers who choose to transfer from a retirement
system to a pension system. See Md. Ann. Code, art. 73B, secs.
11B(5), 14(1)(g) (1988), regarding the Maryland State Employees'
Retirement System; Md. Ann. Code, art. 73B, sec. 89(1)(e) (1988),
regarding the Maryland State Teachers' Retirement System.
11
T…
IRCCourt RulingsSep 25, 1996★ strong match
9950-92; W & A Payroll
Service, Bryen & Bryen, P.A., Tax Matters Partner, docket No.
3221-93; W & A Payroll Service, Bryen & Bryen, P.A., Tax Matters Partner, docket No. 10897-93; and Frank A. Pettisani and
Lucille M. Pettisani, docket No. 23719-93.
T.C. Memo. 1996-435
UNITED STATES TAX COURT
BARRY B. BEALOR AND NANCY…
IRCCourt RulingsJun 17, 1997★ strong match
…nelly had observed that Mr. Traegde did not
have a succession plan for his business or any estate planning,
that the Prime Plan offered death benefits for Mr. Traegde, and
that the Prime Plan would give Mr. Traegde a source of funds to
close his business when he decided to leave.
On October 4, 1988, Mr. Connelly wrote …
IRCCourt RulingsSep 29, 1992★ strong match
his number was in fact higher due to cost of living and other adjustments made annually pursuant to sec. 415(b)(2).
Straight life annuity (all years). 1971 individual annuity table for males with 6-year setback for females.
Joint and 100 percent survivor annuity.
However, the actuary included service with a predecessor…
IRCPrivate Letter RulingsJun 30, 2006related by meaning
…-----------------------------------------------------------------------------------------------
Old Annuity = ---------------------------------------------
New Annuity = --------------------------------------
Settlor = ------------------------------------------------
----------------------------------------------------…
PLR 200742010 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsOct 19, 2007related by meaning
…ution of Bibles in the language
of the reader around the world. Taxpayer has issued charitable gift annuities since date 3 and continues to issue gift annuities, both immediate and deferred, to donors.
Taxpayer follows recommended annuity rates issued by the American Council on Gift
Annuities.
Taxpayer proposes to issu…
IRCCourt RulingsMar 9, 2011related by meaning
…
around 1993 petitioner applied for and was approved to receive monthly payments under two separate annuity contracts.
First, petitioner applied to the Retirement Board (city
board) of the Municipal Employees' Annuity and Benefit Fund of
Chicago (city) for an annuity (city annuity). By letter dated
September 21, 1993, …
IRCCourt RulingsFeb 18, 2004related by meaning
CDs (SFB nonqualified annuity).5 In
Glenbrook Life and Annuity, Flexible Premium Deferred
Annuity Contract, policy number GA295240. Petitioner did not elect to include the Glenbrook annuity as a qualified retirement
plan under sec. 401(a) or 4974(c)(1), nor did it qualify as an
annuity plan under secs. 403(a) and 4974(…
IRCRegulationsSep 9, 2016
…t accruals for Employee B and Employee C in years after 1988, that result from increases in average annual compensation after 1988 and that are attributable to years of service credited for 1981 through 1988, may be treated as provided to Employee B and Employee C in their status as members of the Division M disaggrega…
IRCRegulationsSep 9, 2016
…by averaging fair market value over 4 years. An actuarial valuation is performed as of December 31, 1988. (i) The average value as of December 31, 1988, is computed as follows: 1986 1986 1987 1987 1988 1988 Fair market value: Jan. 1 $150,000 $196,500 $238,000 Contributions $65,000 $62,000 $66,000 Benefit payments (22,0…
IRCCourt RulingsJun 18, 1997related by meaning
…Service due to her disability. Petitioner
subsequently began receiving a FERS disability retirement annuity
(disability annuity). Petitioner received disability annuity
payments during 1992 and 1993 in the amounts of $10,954 and
$11,182, respectively.
Petitioner was told by the U.S. Office of Personnel
Management (OPM)…