IRCPrivate Letter RulingsJul 26, 2013
…ined and transferred to purchase
the new contract.
PLR - 146365-12 5
Rev. Rul. 2005-30, 2005-1 C.B. 1015, holds that if the owner-annuitant of a deferred
annuity contract dies before the annuity starting date, and the beneficiary receives a
dea th benefit under the annuity contract, the amount received by the beneficia…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
is obtained on or before the date the IRS issues a notice of
deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74
…
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011related by meaning
use these regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Code, the notice of proposed rulemaking preceding these regulations was submitted to the Chief Counsel for Advocacy of the Small Busin…
IRCPrivate Letter RulingsAug 8, 2014
…lan 5 has been a church plan since January 1, 2007.
Section 414(e) was added to the Code by section 1015 of ERISA. Section 1017(e) of
ERISA provided that section 414(e) of the Code applied as of the date of ERISA's
enactment. However, section 414(e) of the Code was subsequently amended by section
407(b) of the Multiemp…
IRCCode / StatuteJan 5, 2023related by meaning
(d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and
(d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer.
(d)(2)(C) (C) Reduction not to apply to tax shelters
(d)(…
IRCCourt RulingsSep 30, 1985
…Gegax v. Commissioner, 73 T.C. 329, 334 (1979). Compare Smith v. United States, 460 F.2d 1005, 1014-1015 (6th Cir. 1972).
REG-106251-08 — Proposed regulations under section 423 of the Code provide the requirements that must be satisfied in order for a plan to meet the definition of an employee st… IRCProposed Rules (FR)Proposed Sep 29, 2008
…f determining gain. The donee’s basis for the purpose of determining loss, determined under section 1015(a), is $75 (fair market value of the share at the date of gift).
IRCCourt RulingsJan 9, 2020
…ualification and become qualified for
that year." Pulver Roofing Co. v. Commissioner, 70 T.C. 1001, 1015 (1978). For
this reason we focus our analysis primarily on failures affecting the ESOP's
qualification under section 401(a) for PYE February 28, 2007. We do not
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
89 FR 104915 — Regulations Governing Practice Before the Internal Revenue Service IRCProposed Rules (FR)Proposed Dec 26, 2024related by meaning
in § 10.82.
* * * * *
(d) This section is applicable beginning on [date 30 days after date of publication of final regulations in the
Federal Register ].
Par. 37.
Newly redesignated § 10.85 is amended by:
1. Revising paragraph (a)(2).
2. Adding paragraph (a)(3).
3. Revising paragraph (c).
The revisions and addition rea…
88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation
52.
5 U.S.C. 601
et seq.
Back to Citation
53.
5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551.
Back to Citation
54.
Public Law 104-4, 109 Stat. 48 (Ma…
IRCCourt RulingsJan 12, 1998related by meaning
tely $1,026,855 in U. S.
currency deposited into various bank accounts during the period
January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts
alleging violations of customs reporting requirements.
On January 9, 1992, petitioner entered into a plea a…
IRCCourt RulingsOct 5, 2015
…and become
- 12 -
[*12] qualified for that year." Pulver Roofing Co. v. Commissioner, 70 T.C. 1001,
1015 (1978); see also Martin Fireproofing Profit-Sharing Plan & Tr. v.
Commissioner, 92 T.C. at 1184-1189.
As explained below, the ESOP failed to satisfy the section 401(a)
requirements in two separate ways, either of wh…
Joint BoardRegulationsDec 30, 2016related by meaning
(a)(5) (5) Solicitation of employment as prohibited under § 10.30, the use of false or misleading representations with intent to deceive a client or prospective client in order to procure employment, or intimating that the practitioner is able improperly to obtain special consideration or action from the Internal Reven…
IRCCourt RulingsMay 9, 1988
…msters Fund sought a declaratory judgment that the merger agreement was subject to sections 208 and 1015(c) of ERISA and sought an injunction directing the PBGC to assert jurisdiction over the merger agreement and determine whether the merger was in violation of the standards set forth in ERISA. All parties filed motio…
83 FR 36417 — Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions IRCFinal Rules (FR)Jul 30, 2018related by meaning
ted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business, and no comments were received. Drafting Information
The principal author of these regulations is Charles Gorham of the Office of Associate Chief Counsel (Income Tax and Accounting). Other personnel fr…
88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCProposed Rules (FR)Proposed Nov 20, 2023related by meaning
Section 170(f)(11) requires a qualified appraisal and other documentation for a charitable contribution deduction to be allowed with respect to certain contributions of property. Section 170(f)(11) also includes special rules for contributions of property other than cash (noncash charitable contributions) of more than …
72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner IRCCourt RulingsJun 11, 1979
…). Petitioner argues, citing principally In Re Ferrall’s Estate, 41 Cal.2d 166, 258 P.2d 1009, 1014-1015 (1953), that Citrus did not retain dominion and control over the trust assets since the California courts will interpose their judicial discretion where a trustee does not act in a manner contemplated by the settlor…
IRCCourt RulingsFeb 26, 1964
… insurance or otherwise) for expenses paid for medical care.
The cases of William L. Neill, 17 T.C. 1015, and Charles F. Brown, 25 T.C. 220, are to some extent factually similar to the instant cases in that they considered tax problems of retired members of the Baltimore Police Department. However, they also considered…
87 FR 50240 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations IRCFinal Rules (FR)Aug 16, 2022related by meaning
small business. No comments were received from the Chief Counsel for the Office of Advocacy of the Small Business Administration.
Drafting Information The principal author of these regulations is Seth Groman of the Office of Associate Chief Counsel (Tax Exempt and Government Entities), though other persons in the Treas…