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64 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. PLR 200229001 — Ineligible Plans
    IRCPrivate Letter RulingsJul 19, 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…
  2. 66 T.C. 82 — Sarmir v. Commissioner
    IRCCourt RulingsApr 12, 1976★ strong match
    …1970), affd. 445 F. 2d 985 (10th Cir. 1971), cert. denied 404 U.S. 940 (1971). Petitioner has cited Rev. Rul. 72-440, 1972-2 C.B. 225, wherein the Internal Revenue Service revoked a series of earlier rulings and took the position that an employee would be considered separated from service within the meaning of section …
  3. PLR 202524006 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsJun 13, 2025
    …“group t rust retiree benefit plans,” are qualified retirement plans under § 401(a) of the Internal Revenue Code (Code); governmental retiree benefit plans under § 401(a)(24); certain custodial accounts under § 403(b)(7); retirement income accounts under § 403(b)(9 ); IRAs that are exempt under § 408(e); eligible gover…
  4. Rev. Proc. 2013-8 — 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 ProceduresModified Jan 2, 2013
    etermination Rev. Proc. 93-41 Adoption agreement Rev. Proc. 2011-49 Advisory letter Rev. Procs. 2011-49, 2013-6 Basic plan document Rev. Proc. 2011-49 Determination letter Rev. Procs. 2013-6, 2013-9 Dual-purpose IRA Rev. Procs. 98-59, 2010-48 Group exemption letter Rev. Proc. 80-27 Information letter Rev. Proc. 2013-4 …
  5. 73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner
    IRCCourt RulingsOct 30, 1979related by meaning
    … We sustain respondent's determination. Respondent is authorized to determine the extent to which a revocation of a determination letter will be applied without retroactive effect. Sec. 7805(b); sec. 301.7805-1(b), Proced. & Admin. Regs. 10 We must uphold the retroactive revocation in the instant case unless respondent…
  6. 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 …
  7. 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…
  8. Rev. Rul. 2017-22 — This revenue ruling provides tables of covered compensation under § 401(l)(5)(E) of the Internal Revenue Code and the Income Tax Regulations thereunder, effect…
    IRCRevenue RulingsNov 27, 2017related by meaning
    …yees under certain circumstances relating to the California Wildfires that began on October 8, 2017 Rev. Proc. 2017–59 Rev. Proc. 2017–59 This revenue procedure modifies Rev. Proc. 2015–13, 2015–5 I.R.B. 419, as clarified and modified by Rev. Proc. 2015–33, 2015–24 I.R.B. 1067, and as modified by Rev. Proc. 2016–1, 201…
  9. 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. …
  10. 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…
  11. 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…
  12. 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…
  13. 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…
  14. 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…
  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. 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…
  17. 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 …
  18. 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&…
  19. 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…
  20. 74 T.C. 1029 — E. F. Higgins & Co. v. Commissioner
    IRCCourt RulingsAug 11, 1980
    and Effects,” 52 Minn. L. Rev. 1198 (1968); H. Dederick, “What Constitutes Discrimination in Pension and Profit-Sharing Plans?”, 22 J. Tax. 272(1965). An approach more favorable to petitioners would include in the computations Higgins’ Social Security (PICA) contributions. Liberty Machine Works, Inc. v. Commissioner, 6…