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62 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 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…
  2. PLR 201546012 — Qualified Governmental Excess Benefit Plans
    IRCPrivate Letter RulingsNov 13, 2015
    ed in any way, does not constitute PLR-T-102477-15 8 receipt of income by a cash basis taxpayer. Rev. Rul. 60-31, 1960-1 C.B. 174, as modified by Rev. Rul. 64-279, 1964-2 C.B. 121, and Rev. Rul. 70-435, 1970-2 C.B. 100; see also Rev. Rul. 69-650, 1969-2 C.B. 106, Rev. Rul. 69-649, 1969-2 C.B. 1 06; and Rev. Rul. 71-419…
  3. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975related by meaning
    …; and again supervision and control of the employees was exercised by the professional corporation. Rev. Rui. 75-41 was concerned with whether the individuals were employees of the service corporation for employment tax purposes, while here the issue is whether the individuals are employees of the partnership for purpo…
  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. 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 …
  6. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    …inciple at least, and all of which require the conclusion we reach here unless distinguished or overruled. We think the opinions in each of those cases properly applied the law as written by Congress and we find no reason for departing from them now. We also note that respondent, in his first brief, appears to acknowle…
  7. PLR 201240018 — Included vs. Not Included in Gross Income
    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,…
  8. PLR 201643014 — Qualified Governmental Excess Benefit Plans
    IRCPrivate Letter RulingsOct 21, 2016
    … applies to nonqualified plans of deferred compensation, including excess benefit plans, in various revenue rulings. In Rev. Rul. 60-31, Situations 1 – 3, the Service held that a mere promise to pay, not represented by notes or secured in any way, does not constitute receipt of income by a cash basis taxpayer. Rev. Rul…
  9. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    IRCCourt RulingsOct 19, 1981
    …s through contributions to both defined contribution plans and defined benefit plans subject to the rule of 1.4. Sec. 415(e).
  10. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987
    …130,000 from the trust. The note was payable on demand and was non-interest-bearing. On January 30, 1981, an article published in the Detroit Free Press stated that the shareholders of Cunningham had approved the sale to the New York investors on January 29, 1981, and that the shareholders would receive $18 per share b…
  11. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    …ther cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, where respondent approved a salaried-only classification with respect to an employer who had S3 hourly paid employees and 26 salaried employees…
  12. 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. …
  13. 71 T.C. 1049 — Minnis v. Commissioner
    IRCCourt RulingsMar 26, 1979related by meaning
    …s. * » * ” (Emphasis added.) See also S. Rept. 830, n. 6 supra. It is not without significance that Rev. Rul. 67-258 was not issued until several years after Congress had enacted sec. 72(m) specifically making taxable loans received by owner-employees. See p. 1056 supra. In this context, it appears that respondent has …
  14. 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…
  15. 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…
  16. 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…
  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. 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 …
  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. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976related by meaning
    …ractice is subject to a number of limitations. See Caplin, "Taxpayer Rulings Policy of the Internal Revenue Service: A Statement of Principles,” 20th Ann. N.Y.U. Tax Inst. 1, 19-22 (1962). For example, a private ruling is controlling only with respect to the specific facts presented and may not be relied upon if there …