36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
IRCCourt RulingsFeb 15, 1979related by meaning
loyees, which have less generous plans or no plans at all, this would generally constitute an impermissable discrimination. * * * [Emphasis supplied.] We believe that a fair reading of section 414(b) would have alerted petitioner to the fact that such section requires, inter alia, that an affiliated group- comprised of…
IRCCourt RulingsNov 17, 2016related by meaning
culating the required reduction in the section 415 dollar limitation.
Accordingly, inasmuch as respondent applied this method to calculate the reduced benefit limitation under section 415(b)(2)(C) for the plan, his calculations of the
age 45 limits for tax years 2002 through 2006 are correct.
III. Petitioner's Liabilit…
IRCPrivate Letter RulingsFeb 12, 1999
…nd disbursements method of accounting. See also
Rev. Rul. 69-649,
1969-2 C.B. 106, and Rev. Rul. 69-650, 1969-2 C.B. 106. In Rev. Rul. 72-25, 1972-1
83 FR 49799 — Owner-Participant Changes to Guaranteed Benefits and Asset Allocation PBGCFinal Rules (FR)Oct 3, 2018
…2(c) is $1,000 per month times 0.65 (the factor from column (b) of Table I in § 4022.62(c)(2)), or $650 per month. Multiplying $650 by the category 4 funding ratio of
2/3
(($2 million−$1.5 million)/$0.75 million) produces an estimated category 4 benefit of $433.33 per month.
(D) Because the estimated category 4 benefit…
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…
80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P… ERISAProposed Rules (FR)Proposed Apr 20, 2015
… through July 15, 2014, and November 10, 2014, through December 31, 2014, there were an additional $650,000 of purchases and $400,000 of sales. Thus, total purchases were $1,500,000 (
i.e.,
$850,000 + $650,000) and total sales were $1,400,000 (
i.e.,
$1,000,000 + $400,000) for the management periods.
M now computes the…
IRCCourt RulingsNov 4, 1976related by meaning
loyment is for not more than 20 hours in any one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…
PLR 202417009 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsApr 26, 2024
…in the meaning of the cash receipts and disburseme nts method of
accounting. See also, Rev. Rul. 69-650, 1969-2 CB 106, and Rev. Rul. 69-649, 1969-2 CB
106.
Section 457 contains rules for the taxation of eligible deferred compensation plans of
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…section 170.
1
In the alternative , respondent assert s
that the conservation easement was worth $4,650,000.
1
Unless otherwise indicated, statutory references are to the Internal Revenue
Code, Title 26 U.S.C. (Code), in effect at all relevant times, regulation references are
Served 08/17/26
2
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…iton Group 97% $40,385,950 $548,050
DESE Properties 1.5% 624,525 8,475
1908 Capital PG 1% 416,350 5,650
Dr. Kirkpatrick 0.5% 208,175 2,825
Petitioner did not allocate any of its noncash charitable contributions to
Natural Aggregates, TOFT, Province, or OS LLC.
B. Tax Return Appraisal
Petitioner attached to its 2018 For…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026related by meaning
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
IRCPrivate Letter RulingsNov 5, 2021
…hin the meaning of the cash receipts and disbursements
method of accounting. See also, Rev. Rul. 69-650, 1969-2 CB 106, and Rev. Rul. 69 -
649, 1969-2 CB 106.
IRCCourt RulingsMay 28, 1962related by meaning
ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
PLR 201508001 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsFeb 20, 2015
…hin the meaning of the cash receipts and disbursements
method of accounting. See also, Rev. Rul. 69-650, 1969-2 C.B. 106, and Rev. Rul. 69 -
IRCPrivate Letter RulingsJul 2, 2009
…hin the meaning of the cash receipts and
disbursements method of accounting. See also, Rev. Rul. 69-650, 1969-2 C.B. 106,
and Rev. Rul. 69-649, 1969-2 C.B. 106.
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…18,113,320 paper statements = 464,444,095 DC Statements × 3.9% delivered by paper
5
1
$1.25
22,641,650
DB Statement Distribution
339,403 paper statements = 8,702,640 non-frozen DB Statements × 3.9% delivered by paper
1
1.05
356,373
Frozen Statement Distribution
234,176 paper statements = 6,004,514 frozen DB Statements…
PLR 200302032 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 10, 2003
…hin the meaning of the cash receipts and
disbursements method of accounting. See also, Rev. Rul. 69-650, 1969-2 C.B. 106,
and Rev. Rul. 69-649, 1969-2 C.B. 106.
- 4 -
PLR-158362-01
Section 457(f) does not apply in this case to the amounts contributed to the
employee’s account in the supplemental health benefit or retir…
IRCCourt RulingsDec 16, 1971related by meaning
tion in an inservice training program, apparently identical to the program in the instant case, represent compensation for present or future services. In the case at bar, the pivotal question to be resolved in determining the taxability of the payments received by petitioner is whether the benefits derived from partici…
PLR 200301032 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 3, 2003
…hin the meaning of the cash receipts and
disbursements method of accounting. See also, Rev. Rul. 69-650, 1969-2 C.B. 106,
and Rev. Rul. 69-649, 1969-2 C.B. 106.
Section 457(f) applies in this case to the excess benefit amounts remaining in an
eligible employee’s sick and special leave accounts after the employer has co…