IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
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 RulingsAug 31, 1978related by meaning
41), cert. denied 314 U.S. 621 (1941); see also sec. 1.170-l(c), Income Tax Regs.; sec. 20.2031-1(b), Estate Tax Regs.; sec. 25.2512-1, Gift Tax Regs. The petitioners argue that the parties agreed upon a value of $225,000 for the properties and that this Court is bound to respect the value contractually agreed upon by …
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 RulingsDec 11, 2003related by meaning
f section 6501,
1
section 6651(a)(1),
2
- 37 -
2
(...continued)
(2003) ; Janpol v. Commissioner
, 102 T.C. 499, 503, 505 (1994);
Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, aff…
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 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…
IRCCourt RulingsJan 3, 2011related by meaning
gift tax As Mrs. Cadwell
would be the' hypotlietical' donorain' thé scehario posited by
petitioner, we conclude that section 2523^ does not" apply. - Petiltionery may have meantato ácite as support for his contention
sec tion 102 (a) , which exc ludes f rom- gros s income the value of
property acquired by Égift Howeve…
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-…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
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…
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…
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…
IRCCourt RulingsMar 5, 2018related by meaning
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…
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 RulingsFeb 25, 1959related by meaning
ration from the service” within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners. In Mary Miller, 22 T.C. 293, affd. 226 F. 2d 618, the May Company acquired all the assets of the Strouss-Hirshberg Company in exchange for May Company stock. Three days …
IRCCourt RulingsJan 27, 1998related by meaning
) and (b) of section 4975.
Section 4975 was added to the Internal Revenue Code by title
II of ERISA. ERISA sec. 2003(a), 88 Stat. 971. Section 4975(a) and (b) imposes a two-tier excise tax on prohibited transactions.
The policy behind the enactment of section 4975 was to tax
disqualified persons who engage in self-deal…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006related by meaning
nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A).
(48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
IRCCourt RulingsJun 1, 1987related by meaning
significance save that the words are strung together with syntactical correctness. * * * [Hand, “Thomas Walter Swan,” 57 Yale L. J. 167, 169 (1947).] Section 4975, as added to the Internal Revenue Code by title II of ERISA, Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, imposes two levels of excise tax on a prohibited …