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…
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…
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…
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…
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 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…
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 …
IRCCourt RulingsApr 12, 1976
…f simplicity the partial termination of the plan is referred to as the termination of the plan.
See Rev. Rul. 58-94, 1958-1 C.B. 194; Rev. Rul. 58-95, 1958-1 C.B. 197; Rev. Rul. 58-96,1958-1 C.B. 200; Rev. Rul. 58-97,1958-1 C.B. 201; Rev. Rul. 58-98,1958-1 C.B. 202; Rev. Rul. 58-383,1958-2 C.B. 149; Rev. Rul. 65-147,19…
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…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
… of that section, unless the facts and circumstances are materially identical to those set forth in Rev. Rul. 85-19, 1985-1 C.B. 94; Rev. Rul. 79-67, 1979-1 C.B. 128; Rev. Rul. 77-293, 1977-2 C.B. 91; Rev. Rul. 57-387, 1957-2 C.B. 225; Rev. Rul. 56-584, 1956-2 C.B. 179; or Rev. Rul. 56-556, 1956-2 C.B. 177.
(54) Sectio…
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…
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…