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Go to Rev. Rul. 1971-147 (not yet in the library — opens the official source)
68 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972
    …at the distribution of all funds of a pension trust to the employee participants, each of whom has previously executed and who thereafter carries out a legally enforceable agreement to pay over his distributive share to a new pension trust which, like the former, constitutes a qualified trust under section 401(a) of th…
  2. 89 T.C. 689; 89 T.C. No. 48 — William Bryen Co. v. Commissioner
    IRCCourt RulingsSep 29, 1987related by meaning
    …x Reform Act of 1986 (sec. 4972, I.R.C. 1986) imposing certain taxes for overfunding pension plans. Rev. Rul. 73-206, 1973-1 C.B. 142, revoked by Rev. Rul. 74-385, supra, involved a situation where employer contributions under a money purchase pension plan were geared to employee contributions under the plan. It was de…
  3. 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. …
  4. PLR 200202027 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools
    IRCPrivate Letter RulingsJan 11, 2002related by meaning
    …orary or final regulations are inconsistent with any conclusion in the ruling. See section 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1, 46. However, when the criteria in section 12.05 of Rev. Proc. 2001-1 are satisfied, a ruling is not revoked or modified retroactively except in rare or unusual circumstances. Sincerely…
  5. 69 T.C. 97 — Feroleto Steel Co. v. Commissioner
    IRCCourt RulingsOct 25, 1977
    …payments of Payments of repayment principal interest Dec. 1969.0 $2,656 Dec. 1970.0 10,625 Dec. 28, 1971 .$125,000 10,625 125,000 23,906 Late in 1971 the trustees asked Mr. Smith to ascertain from Seaboard the amount of repayment of the loan and the possibility of repaying the loan over a period of four quarters. Mr. S…
  6. PLR 201840007 — In General
    IRCPrivate Letter RulingsOct 5, 2018related by meaning
    …and accompanied by a penalty of perjury statement executed by an appropriate party, as specified in Rev. Proc. 2018-1, 2018-1 I.R.B. 1, § 7.01(16)(b). This office has not verified any of the material submitted in support of the re quest for ruling, and such material is subject to verification on examination. The Associ…
  7. 73 T.C. 779 — Woodson v. Commissioner
    IRCCourt RulingsFeb 5, 1980
    …eased. Petitioners filed their joint Federal income tax return for 1971 with the Director, Internal Revenue Service Center, Austin, Tex. Curtis B. Woodson and Edna Woodson, married in 1973, filed joint income tax returns for 1973 and 1974 with the Director, Internal Revenue Service Center, Austin, Tex. On or .about May…
  8. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …rement interest 5% 5% 5% Salary scale -0--0--0- Pre-retirement turnover -0--0--0- Mortality (males) 1971 IAM-2 1971 IAM-2 1971 IAM-2 Mortality (females) 1971 IAM-8 1971 IAM-8 1971 IAM-8 Form of benefit , , For purposes of these calculations, Matthews used the following data for Davis: Date of birth . 5/7/34 Date of spo…
  9. 107 T.C. No. 1 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsAug 6, 1996related by meaning
    … are, by contract, mechanical and predictable. Whether the private letter rulings, plus the TAM and Rev. Rul. 76-28, rise to the level of "longstanding administrative practice" is, to say the least, problematical, but in any event, as the Supreme Court has stated in Dixon v. United States , 381 - 29 - U.S. 68, 73 (1965…
  10. 67 T.C. 906 — Jennemann v. Commissioner
    IRCCourt RulingsMar 7, 1977
    OPINION Hall, Judge: Respondent determined a $557.91 deficiency in petitioners’ 1971 income tax. The issues for decision are: (1) Whether this Court is prohibited from taking action herein since it is not established pursuant to the provisions of article III of the Constitution. (2) Whether section 402(a)(2) as applica…
  11. Rev. Rul. 2014-24 — This revenue ruling modifies the list of group trust retiree benefit plans eligible to participate in 81–100 group trusts in accordance with the requirements o…
    IRCRevenue RulingsSep 8, 2014
    …splaced by the disaster and modifies other requirements of § 142(d) to accommodate this suspension. Rev. Proc. 2014–51 Rev. Proc. 2014–51 This revenue procedure provides guidance on certain aspects of an entity’s qualification as a real estate investment trust (REIT) in the context of transactions involving debt secure…
  12. T.C. Memo. 2003-32 — Howard E. Clendenen v. Commissioner
    IRCCourt RulingsFeb 12, 2003related by meaning
    …)(6), Income Tax Regs. 5 Howard E. Clendenen, Inc. v. Commissioner , supra . Petitioners argue that Rev. Rul. 72-368, 1972-2 C.B. 220, and Rev. Rul. 73-79, 1973-1 C.B. 194, support their contention that disqualification in a prior year does not prevent the plan from being qualified in a future year when it meets the re…
  13. 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…
  14. Rev. Proc. 2013-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela…
    IRCRevenue ProceduresModified Jan 2, 2013related by meaning
    …rators or sponsors of a defined benefit plan to obtain approval for a change in funding method, see Rev. Proc. 2000-41, 2000-2 C.B. 371. (7) For requests for the return to the employer of certain nondeductible contributions, see Rev. Proc. 90-49, 1990-2 C.B. 620 (as modified by Rev. Proc. 2013-8). (8) For requests for …
  15. PLR 201519001 — Included vs. Not Included in Gross Income
    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…
  16. Rev. Proc. 2011-44 — This procedure supplements the procedures for requesting a letter ruling under section 414(e) of the Code relating to church plans. This procedure requires tha…
    IRCRevenue ProceduresSep 26, 2011related by meaning
    …ds that constitute a reasonable effort to satisfy the notice requirement. .06 Modification of Prior Revenue Procedures. This revenue procedure modifies Rev. Proc. 2011-4 (and any applicable predecessor revenue procedure) by adding a notice requirement for ruling requests under § 414(e) involving church plans, and requi…
  17. PLR 199934002 — Deferred Compensation
    IRCPrivate Letter RulingsAug 27, 1999
    …al or is not relevant to the issue presented in this technical advice request. 5 The application of Rev. Rul. 54-608 was delayed by Rev. Rul. 55-246, 1955-1 C.B. 68; Rev. Rul. 56-315, 1956-2 C.B. 304; Rev. Rul. 57-28, 1957-1 C.B. 193; and Rev. Rul. 57-325, 1957-2 C.B. 302. Congress further delayed the application of Re…
  18. Rev. Rul. 2011-3 — 2011 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2011 are provided for use in …
    IRCRevenue RulingsJan 24, 2011related by meaning
    …r use in determining contributions to defined benefit plans and permitted disparity. ADMINISTRATIVE Rev. Proc. 2011-11 Rev. Proc. 2011-11 Maximum vehicle values. This procedure provides the maximum vehicle values for use with the special valuation rules under regulations sections 1.61-21(d) and (e). These values are ad…
  19. PLR 200641008 — Governmental Plan
    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 …
  20. 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&…