IRCCourt RulingsApr 10, 1963
year 1958 with the district director of internal revenue in that city. For convenience, Edward C. Heard will hereinafter be referred to as petitioner. Petitioner reached age 62 on April 23, 1956. He was a member of the Armed Forces of the United States and engaged in the military service of the United States from Octob…
IRCCourt RulingsSep 24, 1963
…ddition to and supporting the promissory note.
On August 7, 1958, the district director of internal revenue at Cincinnati ruled that the Trust was a qualified trust under section 401(a) of the 1954 Code and was exempt from income taxation under section 501(a) . That ruling, contained in a letter of August 7, 1958, to p…
IRCCourt RulingsMay 13, 1965
…cient cash to pay its estimated tax liabilities. On December 24, 1958, the Commissioner of Internal Revenue, upon request, issued a ruling letter to the Funkhouser Co. and R. J. Funkhouser Co., Inc., to the effect that the merger of the two Funkhouser corporations and the proposed transfer of assets of the surviving co…
IRCCourt RulingsJul 14, 1992
…t either dies before retirement or survives until retirement. V&E argued that Smith did not use the 1958 CSO mortality table to accurately predict the incidence of preretirement mortality among the plan participants, but rather used it as a means of estimating the cost of providing life insurance coverage for the prere…
IRCPrivate Letter RulingsOct 21, 2016
… applies to
nonqualified plans of deferred compensation, including excess benefit plans, in various
revenue rulings. In Rev. Rul. 60-31, Situations 1 – 3, the Service held that a mere
promise to pay, not represented by notes or secured in any way, does not constitute
receipt of income by a cash basis taxpayer. Rev. Rul…
Rev. Rul. 2006-43 — Government pick-up plans; employer contributions; income tax; prospective application. This ruling describes the actions required for a state or its political … IRCRevenue RulingsAug 28, 2006
…contributions to meet the requirements set forth above in paragraph (1) of Law and Analysis in this revenue ruling. The relief provided above for “pick-ups” implemented prior to August 28, 2006, applies only if the actions taken otherwise complied with Rev. Rul. 81-35, Rev. Rul. 81-36, and Rev. Rul. 87-10, and only if …
Rev. Proc. 2014-8 — User fees for employee plans and exempt organizations. Current guidance for complying with the user fee program of the Service as it pertains to requests for l… IRCRevenue ProceduresJan 2, 2014
istrative scrutiny determination
Rev. Proc. 93–41
Adoption agreement
Rev. Procs. 2011–49, 2013–22
Advisory letter
Rev. Procs. 2011–49, 2013–22, 2014–6 Basic plan document
Rev. Procs. 2011–49, 2013–22
Determination letter
Rev. Procs. 2014–6, 2014–9
Dual-purpose IRA
Rev. Procs. 98–59, 2010–48
Group exemption letter
Rev. …
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026
term rate is set forth for the month of June 2026. See Rev. Rul. 2026-11, page 1570.
Section 467.—Certain Payments for the Use of Property or Services The applicable federal short-term, mid-term, and long-term rates are set forth for the month of June 2026. See Rev. Rul. 2026-11, page 1570.
Section 468.—Special Rules f…
IRCPrivate Letter RulingsMay 8, 2015
. Rev. Rul. 77-85, 1977-1 C.B. 12, Rev. Rul. 80-274, 1980-2 C.B. 27,
Rev. Rul. 81-225, Rev. Rul. 82-54, 1982-1 C.B. 11, Rev. Rul. 2003-91, 2003-2 C.B. 347, and Rev. Rul. 2003-92, 2003-2 C.B. 350. The rulings stand for the proposition that
contract holders possessing control over the investment of the separate account a…
IRCPrivate Letter RulingsOct 13, 2006
…ge for such insurance is unreasonably large in
relation to the total charges under the contract.
In Rev. Rul. 75-302 , 1975-2 C.B. 86, Rev. Rul. 75-303, 1975-2 C.B. 87, and Rev. Rul. 76 -
481, 1976-2 C.B. 82, taxpayers were allowed a current deduction of payments for future medical
care extendi ng substantially beyond …
Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U… IRCNoticesApr 21, 2014
…, must a qualified retirement plan be amended to reflect the outcome of Windsor and the guidance in Rev. Rul. 2013–17 and this notice?
A–4. Whether a plan must be amended to reflect the outcome of Windsor and the guidance in Rev. Rul. 2013–17 and this notice depends on the terms of the specific plan, as described in Q&…
Rev. Rul. 2008-13 — Performance-based compensation. This ruling holds that compensation paid to an executive is not qualified performance-based compensation for purposes of sectio… IRCRevenue RulingsMar 10, 2008
INCOME TAX
Rev. Rul. 2008-11 Rev. Rul. 2008-11
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2008.
Rev. Rul. 2008-12 Rev. Rul. 2008-12
Application o…
IRCCourt RulingsMay 20, 1976
Rev. Rul. 69-421 (Part 2(j)(l)), 1969-2 C.B. 59, 64, sets forth respondent’s position rejecting the prior service of self-employed individuals — partners and sole proprietors — for both prior service benefits and eligibility requirements. He, therefore, concludes that the prior services of a sole proprietor cannot be c…
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
l Revenue Service Restructuring and Reform Act of 1998, and the American Jobs Creation Act of 2004.
EMPLOYMENT TAX
Rev. Rul. 2009-39 Rev. Rul. 2009-39 94X examples revenue ruling. This revenue ruling illustrates the application of the interest-free adjustment and claim for refund processes under the final regulations p…
IRCCourt RulingsJul 3, 1974
…rationale to support the relevance of this distinction. The reaction of Congress to the issuance of Rev. Rul. 54-608 provides further support for our conclusion that a vacation plan is not a deferred-compensation plan within the intendment of section 404. In 1958, Congress enacted section 97 of the Technical Amendments…
IRCPrivate Letter RulingsOct 5, 2012
…counting Principles, a synthetic lease is viewed as a secured loan by the IRS for tax purposes."
20
Rev. Rul. 77-85, 1977-1 C.B. 12; Rev. Rul. 80-274, 1980-2 C.B. 27; Rev. Rul. 81-225, 1981-2 C.B. 12; and Rev. Rul. 82-55, 1982-1 C.B. 12. See
also Rev. Proc. 99-44, 1999-2 C.B. 598.
21
Rev. Rul. 2003-91, 2003-2 C.B. 347,…
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007
INCOME TAX
Rev. Rul. 2007-34 Rev. Rul. 2007-34
LIFO; price indexes; department stores. The March 2007 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referen…
Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul… IRCNoticesDec 27, 2005
…)(v) of the Code and the applicable mortality table under § 417(e)(3)(A)(ii)(I) of the Code. (New). Rev. Rul. 2002-42, 2002-1 C.B. 76, provides guidance with respect to a situation where a money purchase pension plan is merged or converted into a profit sharing plan.
Rev. Proc. 2002-21, 2002-1 C.B. 911, provides guidan…