IRCCourt RulingsMay 19, 1986related by meaning
urt has taken in later cases, such as those noted earlier herein, is a matter that we need not consider. The plain fact is that it is distinguishable. We find support, at least to some extent, for our conclusion that the provision under attack is constitutional in the numerous recent cases interpreting section 2035 wit…
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…
81 FR 20946 — Definition of the Term “Fiduciary”; Conflict of Interest Rule-Retirement Investment Advice ERISAFinal Rules (FR)Apr 8, 2016related by meaning
…-1, Parts II-V; PTE 77-4; PTE 80-83; PTE 83-1: PTE 84-24; and PTE 86-128.
Back to Citation
54.
The revoked exemptions include PTE 75-1, Parts I(b) and (c); PTE 75-1, Part II(2); and parts of PTE 84-2 and PTE 86-128.
Back to Citation
55.
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. …
IRCCourt RulingsMay 2, 1978
… to and paid the penalty prescribed by section 72(m)(5)(B) for such distributions. From January 24, 1969, to December 1969, the petitioner did not participate in any qualified retirement plan. In December 1969, the partnership signed a joinder to the master plan maintained by Pittsburgh National Bank and thereby establ…
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…
IRCCourt RulingsMay 30, 1984
…e if it meets the requirements of that provision. Although many organizations apply to the Internal Revenue Service for "exemption certificates,” the law does not require them to do so. * * * [H. Rept. 91-413, at 37 (1969), 1969-3 C.B. 200, 224. See also S. Rept. 91-552, at 53 (1969), 1969-3 C.B. 423, 458.][]
The city …
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…
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…
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…
Rev. Rul. 2005-55 — Profit-sharing plan; retiree health accounts; nonforfeitability; prospective application. This ruling holds that a sub-account within a profit-sharing plan tha… IRCRevenue RulingsAug 15, 2005related by meaning
…t 2005-58
A list is provided of organizations now classified as private foundations. EMPLOYMENT TAX
Rev. Proc. 2005-51
This procedure provides guidance to persons who may be required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Code, and who may be required under section 6707A(e) to disclose …
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 …
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 …
IRCPrivate Letter RulingsJul 19, 2002related by meaning
…orary or final regulations are inconsistent with any
conclusion in the ruling. See section 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1, 46. However, when the criteria in section 12.05 of Rev. Proc. 2001-1 are satisfied, a ruling
is not revoked or modified retroactively except in rare or unusual circumstances.
Sincerely…
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. 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 RulingsFeb 28, 1977related by meaning
. Rul. 67-164, 1967-1 C.B. 88; Rev. Rul. 69-190, 1969-1 C.B. 131. However, as we shall point out shortly, the present case is sharply distinguishable. In Rev. Rul. 67-164, a trustee distributed to the beneficiaries of an exempt profit-sharing trust the entire amounts standing to their accounts on the date of distributi…
IRCCourt RulingsMar 26, 1979related by meaning
…other day. We recognize that our reasoning and the conclusion which flows therefrom are contrary to Rev. Rul. 67-258, supra. But it has long been held that the courts are not bound by revenue rulings since, as we stated in Estate of Lang v. Commissioner, 64 T.C. 404, 407 (1975), on appeal (9th Cir., Jan. 6, 1976), they…
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…