PLR 201616012 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsApr 15, 2016
…e unfunded
liabilities as of June 1,
2014, for the
above~named Plan which are described in sections 431 (b)(2)(B)
and 431 (b)(4)
of the Internal Revenue Code ("Code"), and sections 304(b)(2)(8)
and 304(b)(4)
of the Employee Retirement Income Security Act of 1974
("ERISA"). This extension is effective with the plan year…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
PLR 201526024 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsJun 26, 2015
Significant Index Number 0431.00-00
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
Re:
(Plan No.
EIN:
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
APR 0 2 2015
) ("Plan")
201126024
Taxpayer=
Dear
This
letter constitutes notice that approval has been granted for your request for
a 5-year autom…
PLR 201526025 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsJun 26, 2015
Significant Index Number 0431.00-00
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
Re:
(Plan No.
EIN:
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
APR 0 2 2015
) ("Plan")
201526025'
Taxpayer=
Dear
This
letter constitutes notice that approval has been granted for your request for
a 5-year auto…
IRCCourt RulingsDec 24, 1985related by meaning
y meaningful "binding obligation” could have been entered into between petitioner and Charter which would have any controlling effect in the premises. So far as respondent’s reliance on Rev. Rui. 73-124 is concerned, we note that revenue rulings do not have the force of law and are merely statements of the Commissioner…
IRCCourt RulingsJan 3, 2011related by meaning
,000," and ( ) the cost of
term life insurance on petitioner's life for 2004 of $13,510.
Petitifoner timely filed a petition in this Court.
Discussion Rule 121(a) allows a party to move "for a summary
adjudication in the moving party's favor upon all or any part of
the 1 gal issues in controv rsy." Rule 121(b) directs …
PLR 201446037 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsNov 14, 2014
Significant Index Number 0431.00-00
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
Re:
(Plan No.
EIN:
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
AUG 2 0 2014
) ("Plan")
201446037
Taxpayer=
Dear
This
letter constitutes notice that approval has been granted for your request for
a 5-year autom…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
PLR 201446034 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsNov 14, 2014
Significant Index Number 0431.00-00
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
Re:
(Plan No.
EIN:
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
AUG 2 0 2014
) ("Plan")
201446034
Taxpayer=
Dear
This letter constitutes notice that approval has been granted for your request
for
a 5-year autom…
PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans IRCPrivate Letter RulingsAug 8, 2014related by meaning
arding
enforceable claims of the parties; and (ii) the parties'
assessments
of the relative strengths of their positions. We further conclude that the final settlement agreement approved by Court Order is within the range of reasonable
outcomes under the governing instruments and applicable State law.
Therefore, based …
PLR 201440033 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsOct 3, 2014
~ Significant Index Number 0431.00-00
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
f1J440033
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
Re:
(Plan No.
EIN:
JUL 1 0 2014
) ("Plan")
Taxpayer=
Dear
This letter constitutes notice that approval has been granted for your request for
a 5-year aut…
PLR 201432033 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsAug 8, 2014
---------
Significant Index Number 0431.00-00
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
Re:
(Plan No.
EIN:
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
MAY 1 3 2014
) ("Plan")
201432088
Taxpayer=
Dear
This
letter constitutes notice that approval has been granted for your request for
a 5-…
PLR 201432031 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsAug 8, 2014
,
Significant Index Number 0431.00-00
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
201432031
TAX EXEMPT AND
GOVERNMENT ENTITIES
MAY 1 3 2014
DIVISION
Re:
(Plan No.
EIN:
) ("Plan")
Taxpayer=
Dear
This letter constitutes notice that approval has been granted for your request for
a 5-year aut…
IRCCourt RulingsNov 14, 1996related by meaning
rst articulated.
3
As a
consequence, we set forth that analysis in order to bring into
focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid"
when the letter of credit was purchased on March 13, 1992.
Statutory Framework
The parties have stipula…
PLR 201432034 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsAug 8, 2014
Significant Index Number 0431.00-00
TAX EXEMPT AND
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
;tOl432034
GOVERNMENT ENTITIES
DIVISION
Re:
(Plan No.
EIN:
MAY 1 3 2014
) ("Plan")
Taxpayer=
Dear
This
letter constitutes notice that approval has been granted for your request for
a 5-year auto…
PLR 201430024 — Minimum Funding Standards for Multiemployer Plans IRCPrivate Letter RulingsJul 25, 2014
Significant Index Number 0431.00-00
Re:
(Plan No.
EIN:
) ("Plan")
Department d The Treasury
Internal Revenue Service
Washington,
D.C. 20224
MAY 0 1 2014
201430024
Taxpayer=
Dear
This letter constitutes notice that approval has been granted for your request for
a 5-year automatic extension for amortizing the unfunded li…
IRCCourt RulingsJan 14, 2002related by meaning
employment tax
of $1,857. Petitioners had three qualifying children during 1997
- 4 -
and claimed an EIC of $2,404. Petitioners did not report the IRA distribution.
Respondent determined that petitioners’ gross income should
be increased by the amount of the $10,452 IRA distribution. The
adjustment increased petitioner…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
IRCCourt RulingsOct 19, 2010related by meaning
tter of local law and a
State court's determination with regards to such assignment is
not reviewable by this Court);9 Chambers v. Commissioner, supra 9This Court recognizes that in Commissioner v. Estate of
Bosch, 387 U.S. 456, 465 (1967), the Court held that where the
Federal estate tax liability turns upon the chara…