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…
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…
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…
REG-130241-04 — Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualifie… IRCProposed Rules (FR)Proposed Jul 5, 2005
…ermitting the limitations of section 415 to be incorporated by reference under the terms of a plan.
Rev. Rul. 95-6, 1995-1 C.B. 80, and Rev. Rul. 2001-62, 2001-2 C.B. 632, (superseding Rev. Rul. 95-6) provide mortality tables to be used to make certain form adjustments to benefits under a defined benefit plan for purpo…
IRCCourt RulingsNov 29, 1993
…operty law see Capíes, “Erisa, Preemption and California Community Property Law,” 22 Santa Clara L. Rev. 33 (1982); Quirk, “State Community Property laws: Coping with Federal Tax and Pension Laws,” 19 Gonzaga L. Rev. 481, 500-509 (1983/84); Comment, “The Employee’s Retirement Income Security Act of 1974 — The Spouse’s …
Rev. Rul. 2007-67 — Mortality tables; single sum distributions; section 417(e)(3) of the Code. This ruling pertains to the mortality table to be used when calculating a single sum… IRCRevenue RulingsNov 26, 2007
…f 2007 applies to notices under section 6404(g)(1) that are provided on or after November 26, 2007.
Rev. Proc. 2007-67 Rev. Proc. 2007-67 Change in accounting method. This document allows taxpayers, under certain conditions, to request to revise the year of change for a Form 3115, Application for Change in Accounting M…
Rev. Rul. 2009-2 — 2009 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2009 are provided for use in … IRCRevenue RulingsJan 12, 2009
INCOME TAX
Rev. Rul. 2009-1 Rev. Rul. 2009-1
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 January 2009.
Notice 2009-4 Notice 2009-4
Basis determination. …
Rev. Rul. 2004-65 — Post-retirement health benefits; waiver. This ruling holds that an employer has reduced retiree health coverage, within the meaning of section 420(c)(2)(E) of … IRCRevenue RulingsJul 6, 2004
INCOME TAX
Rev. Rul. 2004-63 Rev. Rul. 2004-63
Special use value; farms; interest rates. The 2004 interest rates to be used in computing the special use value of farm real property for which an election is made under section 2032A of the Code are listed for estates of decedents.
Rev. Rul. 2004-66 Rev. Rul. 2004-66
Fede…
78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property IRCFinal Rules (FR)Sep 19, 2013
…ents that distinguished certain depreciable property from materials and supplies. See, for example, Rev. Rul. 2003-37 (2003-1 CB 717) (permitting taxpayers to treat certain rotable spare parts used in a service business as depreciable assets); Rev. Rul. 81-185 (1981-2 CB 59) (concluding that major standby emergency spa…
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, 2011
INCOME TAX
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 adjusted for inflation and must be adjusted annually by reference to the Consumer Price Ind…
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…
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…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…luding the LA County General Land Use Plan and
the Malibu/Santa Monica Mountains Interim Area Plan (1981 Interim
Area Plan) and the Malibu Local Coastal Program Land Use Plan (1986
Malibu LCP L UP ) . At the time the application was deemed complete ,
development in the northern portion was governed primarily by the
198…
IRCRegulationsSep 9, 2016
…e has no vested right to any employer-derived benefit under the plan. The plan does not contain the rule described in section 411(a)(6)(B) (relating to the requirement of one year of service after a one-year break in service). (ii) Employee A commences employment with the X Corporation on January 1, 1977. Employee A's …
IRCCourt RulingsSep 25, 1996
…ency to Dr. Crescenzo,
disallowing this claimed loss deduction.
Post-1980 Transactions of MIT 80
In 1981, Machise "advanced" $6,509 in cash to MIT 80. MIT
80 then paid a net $2,109.97 in payroll taxes. On its
partnership return for 1981, MIT 80, under its cash method of
accounting, reported a loss of $2,110, which is t…
Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2023related by meaning
ear of a tax-exempt employees’ trust (see Rev. Proc. 87-27, 1987-1 CB 769);
(6) The tax consequences of prohibited transactions under §§ 503 and 4975; (7) Whether individual retirement accounts established by employers or associations of employees meet the requirements of § 408(c) (see Rev. Proc. 87-50; Rev. Proc. 92-3…
IRCCourt RulingsOct 6, 1988
… forming her estate plan and the intent of Congress in enacting the unlimited marital deduction.
In 1981 section 2056(c), which limited the marital deduction otherwise available under section 2056(a), was repealed by section 403(a)(1)(A) of the Economic Recovery Tax Act of 1981, Pub. L. 97-34, 95 Stat. 301, effective f…
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…
PLR 199925042 — Deduction for Contributions of Employer to an Employee's Trust or Annuity Plan and Compensation Under a Deferred-Payment Plan (Deduct. v. Not Deduct.) IRCPrivate Letter RulingsJun 25, 1999
16 T.C. 244 (1951), aff'd per curiam , 194 F. 2d 541 (6th Cir.
19
1952); Rev. Rul. 60-31, Situation 4
. In Rev. Rul. 72-25, 1972-1 C.B. 127, and Rev. Rul. 68-99, 1968-1 C.B. 193, an employee does not receive income as a result of
the employer's purchase of an insurance contract to provide a source of funds for
deferre…