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79 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-161 — Roblene, Inc. v. Commissioner
    IRCCourt RulingsMay 13, 1999
    ted on August 9, 1985, and its principal business activity is real estate sales. It is the employer and plan administrator with respect to the ESOP, a defined contribution plan. Petitioner established the ESOP and the trust as of August 12, 1985, effective for plan years beginning on and after August 12, 1985. The plan…
  2. T.C. Memo. 2004-40 — Anthony J. & Denise D. Sadberry v. Commissioner
    IRCCourt RulingsFeb 18, 2004related by meaning
    …e issues for decision are:- (1) Whether petitioners realized gross income under section 72 from two annuity distributions; (2) whether petitioners are liable for the 10-percent penalty on premature distributions from nonqualified annuities under section 72(q);3 and (3) whether petitioners are liable for the 20-percent …
  3. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997
    …arying amounts of Harrah Bancshares stock. In an attempt to repay the 1982 plan loan, on August 19, 1985, petitioner transferred to the Hickman corporation profitsharing plan 5,000 shares of Harrah Bancshares stock (Harrah Bancshares profit-sharing plan stock) and certain real property located in Oklahoma County, Oklah…
  4. PLR 202052005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 24, 2020related by meaning
    this office, a copy of this letter is being sent to your authorized representative. Sincerely, Rebecca L. Baxter Senior Technician Reviewer, Branch 4 (Financial Institutions & Products) cc:
  5. 105 T.C. No. 29 — John U. & Sylvia Fazi v. Commissioner
    IRCCourt RulingsDec 19, 1995
    nding in 1985, 1986, and 1987 due to the corporation's failure to adopt formally - 5 - a plan complying with changes made in the applicable law by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, 96 Stat. 324; the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, 98 Stat. 494; and the …
  6. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    beginning in 1985, which was more than 3 years prior to the date on which the property was sold. Generally, sections 1001 and 61 require a taxpayer to recognize in the year of the sale gain realized on the sale of property. Section 1034, however, allows a taxpayer, in certain circumstances, to defer recognition of gain…
  7. 89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction
    IRCProposed Rules (FR)Proposed Mar 25, 2024related by meaning
    …r transaction. Back to Citation 2.  Section 72 governs the tax treatment of payments received as an annuity, and generally causes only the portion of each payment in excess of the investment in the contract (basis) to be included in the recipient's gross income. Back to Citation 3.  The beneficiary also claims that sec…
  8. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …. 274(d); sec. 1.274-5T(a), (c) (1), Temporary Income Tax Regs., 50 Fed. Reg. 46006, 46016 (Nov. 6, 1985). To meet the adequate records requirements of section 274(d), a taxpayer must maintain an account book, a log, or other documentary evidence which, in combination, is sufficient to - 57 - establish each element of …
  9. Ann. 2009-85 — Temporary closing of the determination letter program for adopters of pre-approved defined benefit plans. The Service announces that it will temporarily stop a…
    IRCAnnouncementsDec 21, 2009related by meaning
    …or adopting the restated pre-approved defined benefit plans will be returned to the applicant. This announcement does not affect the ability of adopting employers to apply for determination letters on Form 5307 for pre-approved defined contribution plans. See Announcement 2008-23, 2008-1 C.B. 731. This announcement als…
  10. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999
    … which it approved revisions to the FUH plan. These meetings included: (1) July 25, 1983, March 11, 1985, and October 28, 1985, at which the committee approved the FUH plan; and (2) July 23, 1984, at which the committee agreed to use $225,000 received from Travelers for the first death under the plan to buy six or seve…
  11. 79 FR 37633 — Longevity Annuity Contracts
    IRCFinal Rules (FR)Jul 2, 2014related by meaning
    …e applicable. Back to Citation 2.  These illustrations assume a three-percent interest rate, no pre-annuity-starting-date death benefit, use of the Annuity 2000 Mortality Table for males and females, no indexation of the annuity stream for inflation, and no load for expenses. (If the annuity were provided under an empl…
  12. Rev. Proc. 2015-36 — This revenue procedure modifies Rev. Proc. 2011–49 by expanding the scope of the pre-approved program to include defined benefit plans containing cash balance …
    IRCRevenue ProceduresJul 6, 2015
    …cceptability of the form of pre-approved plans were set forth in Rev. Proc. 2011–49 (as modified by Ann. 2012–3, 2012–4 I.R.B. 335; Ann. 2013–37, 2013–34 I.R.B. 155; Ann. 2014–4, 2014–7 I.R.B. 523; Ann. 2014–41, 2014– 52 I.R.B. 979; and Rev. Proc. 2015–6, 2015–1 I.R.B. 194). Sections 6.03(4) and 16.03(4) of Rev. Proc. …
  13. PLR 202341003 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsOct 13, 2023related by meaning
    - ------------------------------- ------------------------------- -------------------------- --------------------------- --------------- ------------- ------------------------------------------------------- ------------------------------- -------------------------- ---------------------------------- -------------------…
  14. Ann. 2015-19 — This announcement describes future changes to the determination letter program for qualified individually designed plans and sets forth an intended transition …
    IRCAnnouncementsAug 10, 2015related by meaning
    … on or before October 1, 2015. Comments should be mailed to Internal Revenue Service, CC:PA:LPD:PR (Announcement 2015–19), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, D.C. 20044, or sent electronically to notice.comments@irscounsel.treas.gov. Please include “Announcement 2015–19” in the subject line of …
  15. 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
    …f the optional forms of benefit available to that individual. In response to questions raised, this announcement clarifies that reasonable estimates may be used in determining the amount of the normal form of benefit available to a participant under the generalized notice method of disclosure. In addition, a plan may c…
  16. PLR 202352012 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 29, 2023related by meaning
    ) provides that it may not be used or cited as precedent. Taxpayer must attach a copy of this letter ruling to any tax return to which it is relevant. In accordanc e with a power of attorney on file in this office, a copy of this ruling is being furnished to your authorized representatives. Sincerely, Rebecca L. Baxter…
  17. 85 T.C. 1031; 85 T.C. No. 60 — Anesthesia Service Medical Group, Inc. v. Commissioner
    IRCCourt RulingsDec 24, 1985
    …effect during the years in issue. See Stearns-Roger Corp. v. United States, 774 F.2d 414 (10th Cir. 1985); Beech Aircraft Corp. v. United States, an unreported case (D. Kan. 1984, 54 AFTR 2d 84-6173, 84-2 USTC par. 9803); Mobil Oil Corp. v. United States, 8 Cl. Ct. 555 (1985); cf. Crawford Fitting Co. v. United States,…
  18. PLR 202233012 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsAug 19, 2022related by meaning
    t it may not be used or cited as precedent. A copy of this letter ruling must be attached to any tax return to which it is relevant. PLR - 125556-21 6 In accordance with a power of attorney on file in this office, a copy of this ruling is being furnished to your authorized representatives. Sincerely, Rebecca L. Baxter …
  19. PLR 200226001 — Tax on Reversion of Qualified Plan Assets to Employer
    IRCPrivate Letter RulingsJun 28, 2002
    …version occurs until the employer is in receipt of such excess amounts. H.R. Rep. No. 99426 at 756 (1985) (1986-3 C.B. Vol. 2 at 756) states in this regard: However if assets remain in a defined benefit plan upon plan termination as a result of actuarial error, then after the plan has satisfied all liabilities those as…
  20. PLR 202426001 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsJun 28, 2024related by meaning
    nce with the power of attorney on file with this office, we are sending a copy of this letter to the Taxpayer’s authorized representatives. Sincerely, Elizabeth M. Hill Assistant to the Branch Chief, Branch 4 (Financial Institutions and Products) Cc: ----------------------- -------------------------------------- --- --…