IRCPrivate Letter RulingsMay 16, 2008related by meaning
Internal Revenue Service Department of the Treasury
Washington, DC 20224
Number: 200820009
Release Date: 5/16/2008
Index Number: 72.02-00, 72.20-00, 401.0000, 401.06-00, 402.00-00,
403.00-00, 408.06-00,
4973.00-00, 4979.00-00
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Rev. Proc. 2013-22 — This revenue procedure sets forth the procedures of the Internal Revenue Service for issuing opinion and advisory letters for § 403(b) pre-approved plans (that… IRCRevenue ProceduresSuperseded Apr 29, 2013
…ervice will not treat a § 403(b) plan as failing to satisfy the requirements of § 403(b) during the 2009 calendar year, provided that: (1) on or before December 31, 2009, the sponsor of the plan has adopted a written § 403(b) plan that is intended to satisfy the requirements of § 403(b) (including the 2007 regulations)…
T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (… IRCTreasury DecisionsMar 7, 2005related by meaning
Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified.
EXEMPT ORGANIZATIONS
T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
Notice 2009-3 — This notice provides relief during 2009 for sponsors of section 403(b) plans with respect to the requirement to have a written section 403(b) plan in place by … IRCNoticesJan 12, 2009
Notice 2009-3
Relief From Immediate Compliance With 2009 § 403(b) Written Plan Requirement
This notice provides relief during 2009 for sponsors of § 403(b) plans with respect to the requirement to have a written § 403(b) plan in place by January 1, 2009. This notice also briefly describes other programs the Service int…
IRCCourt RulingsSep 25, 1996related by meaning
…ecourse notes in similar tax-shelter situations occur,
for example, in Fritz v. Commissioner
, T.C. Memo. 1991-176;
Maultsby v. Commissioner
, T.C. Memo. 1989-659; Diego Investors-IV
v. Commissioner
, T.C. Memo. 1989-630.
debt for tax purposes. See, e.g., Bryant v. Commissioner
, 790
F.2d 1463, 1466 (9th Cir. 1986), af…
Notice 2009-20 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesMar 23, 2009
…ng target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from February 2009 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of February 2009 are, respectively, 5.24, 7.07, and 7.08. The three 24-month average corporate bond segment…
IRCCourt RulingsJan 17, 2024related by meaning
United States Tax Court
T.C. Memo. 2024-6
CLAIR R. COUTURIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed January 17, 2024.
—————
Michael Eddison Romero , Alvah Lavar Taylor, Daniel W. Soto , and
Jonathan T. Amitrano , for petitioner.
Hilary E. March , Laura A. Pr…
Notice 2009-39 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesMay 4, 2009
…nding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from March 2009 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of March 2009 are, respectively, 5.70, 7.53, and 7.85. The three 24-month average corporate bond segment ra…
Notice 2009-45 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesJun 1, 2009
…nding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from April 2009 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of April 2009 are, respectively, 5.12, 7.15, and 6.92. The three 24-month average corporate bond segment ra…
T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a … IRCTreasury DecisionsMay 7, 2007related by meaning
INCOME TAX
Rev. Rul. 2007-29 Rev. Rul. 2007-29
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 May 2007.
Announcement 2007-44 Announcement 2007-44
This anno…
Notice 2009-56 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesJun 22, 2009
…funding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from May 2009 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of May 2009 are, respectively, 4.27, 7.00, and 6.77. The three 24-month average corporate bond segment rate…
IRCCourt RulingsMar 6, 2001related by meaning
…T.C. 732, 747 (1964),
affd. on this issue 356 F.2d 883 (5th Cir. 1966); Rice v.
Commissioner
, T.C. Memo. 1994-204.
Moreover, even if respondent should be deemed to have
performed a second inspection on the bartering proceeds issue
without prior notification that petitioner did not waive,
invalidation of the notice of …
IRCCourt RulingsMar 23, 2009related by meaning
Rul . 2002-62, 2002-2 C .B . 710 ;, Notice
89-25, Q&A-12, 1989-1 C .B . 662, 666 .
7 -
Section 72(t)(4)4 provides that the-exception found in section 72(t)(2)(A)(iv) is not applicable if the series of substantially
equal periodic payments is subsequently modified (other than by
reason of death or disability) before th…
IRCCourt RulingsSep 3, 1998related by meaning
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
Notice 2009-88 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesNov 23, 2009
…rs Beginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
November 2009 4.36 3.93 4.58 MINIMUM PRESENT VALUE SEGMENT RATES
Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-mon…
IRCPrivate Letter RulingsNov 26, 1999related by meaning
…/1999
CC:EBEO:FS:Br.7
UILC: 419.12-02
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR DISTRICT COUNSEL, ILLINOIS DISTRICT
FROM: Michael J. Roach
Chief, Branch 7, Office of Associate Chief Counsel (EBEO)
CC:EBEO:BR7
SUBJECT:
This Field Service Advice responds to your memorandum dated March 2…
T.D. 9472 — Final regulations under section 4980F of the Code provide guidance relating to the section’s application to a plan amendment that is permitted to be effective … IRCTreasury DecisionsDec 21, 2009
…termination letters on Form 5307 for pre-approved defined contribution plans.
EMPLOYMENT TAX
Notice 2009-80 Notice 2009-80 2010 social security contribution and benefit base; domestic employee coverage threshold. The Commissioner of the Social Security Administration has announced (1) the OASDI contribution and benefit…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
addition, the notice invites comments from the public regarding all aspects of these provisions.
ADMINISTRATIVE
Rev. Proc. 2007-21 Rev. Proc. 2007-21 This procedure provides guidance to persons against whom a penalty under section 6707 or 6707A of the Code is assessed, and who may request rescission of those penalties…
Ann. 2009-89 — Remedial amendment period and reliance for section 403(b) plans. This announcement provides for a remedial amendment period and reliance for employers that, pu… IRCAnnouncementsDec 28, 2009
Announcement 2009-89
Remedial Amendment Period and Reliance for Section 403(b) Plans
Within the next few months, the Service expects to publish a revenue procedure for obtaining an opinion letter that the form of a prototype or other “pre-approved plan” meets the requirements of § 403(b) of the Internal Revenue Code an…