68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner IRCCourt RulingsSep 12, 1977
…tion at the end of the year and filed its 1972 Form 4848, "Annual Status Report,” with the Internal Revenue Service.
IRCCourt RulingsJun 13, 1977
…ckett’s employees were covered. For the second quarter of such fiscal year (Nov. 1, 1971 — Jan. 31, 1972), Crockett and Dorsey were covered the entire quarter, Fowler was covered as of Dec. 1, 1971, and Richardson need not be counted because she had not satisfied the minimum service requirement. Therefore, on at least …
IRCCourt RulingsSep 19, 1978related by meaning
…d part of our analysis, relating to the effect of unforeseen circumstances on respondent’s right to revoke his prior ruling. Respondent has publicly announced that a ruling will, in the absence of unusual circumstances, not be revoked retroactively. Statement of Procedural Rules, 26 C.F.R. sec. 601.201 (1977); Rev. Pro…
IRCPrivate Letter RulingsFeb 5, 1999
ions.
Various revenue rulings have considered the tax consequences of nonqualified deferred compensation arrangements. Rev. Rul.
60-31, Situations 1-3 , 1960-1 C.B. 174, holds that a mere promise to pay, not represented by notes or secured in any way, does not
constitute receipt of income within the meaning of the cash…
IRCPrivate Letter RulingsMar 26, 1999
ion arrangements. Rev. Rul. 60-31, Situations 1-3
, 1960-1 C.B.
174, holds that a mere promise to pay, not represented by notes or secured in any way, does not constitute receipt of income within the meaning of the cash receipts and
disbursements method of accounting. See also, Rev. Rul. 69-650, 1969-2 C.B. 106,
and Re…
Rev. Proc. 2014-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela… IRCRevenue ProceduresJan 2, 2014related by meaning
…7). These matters are generally handled by the Employee Plans Determinations program as provided in Rev. Proc. 2014–6, this Bulletin, Rev. Proc. 93–10 and Rev. Proc. 93–12. Although the Employee Plans Technical office will not ordinarily issue rulings on matters involving plan qualification, a ruling may be issued wher…
IRCPrivate Letter RulingsMar 12, 1999
…he taxpayer's control of its receipt is subject to
substantial limitations or restrictions.
Various revenue rulings have considered the tax consequences of nonqualified deferred compensation arrangements. Rev. Rul.
60-31, Situations 1-3
, 1960-1 C.B. 174, holds that a mere promise to pay, not represented by notes or se…
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 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. 2016-27 — This revenue procedure contains revised procedures for applications for a suspension of benefits under a multiemployer defined benefit pension plan that is in … IRCRevenue ProceduresMay 9, 2016related by meaning
…ection 305(e)(9) of ERISA, as well for purposes of § 432(e)(9) of the Code. [3] Section 7.01(13) of Rev. Proc. 2016–1 provides that the following parties may be authorized representatives if appropriately accredited or authorized: attorney, certified public accountant, enrolled agent, enrolled actuary, and enrolled ret…
IRCCourt RulingsJul 25, 1984
…(Supp.) 80, 129. Both parties have devoted considerable attention on brief to a discussion of three revenue rulings: Rev. Rul. 72-439, 1972-2 C.B. 223 (partial termination occurred when a union contract caused 120 of the plan’s 170 participants to become ineligible to participate in the plan); Rev. Rul. 73-284, 1973-2 …
IRCCourt RulingsSep 29, 1987
…ae for determining the required annual contributions under the plans in issue in those rulings. See Rev. Rul. 74-385, 1974-2 C.B. 130; Rev. Rul. 73-379, 1973-2 C.B. 124; Rev. Rul. 72-302, 1972-1 C.B. 110. In each of these rulings, the analysis focuses on whether the plan formula for determining the required annual cont…
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,…
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…