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 …
Notice 2014-77 — This notice contains the 2014 Cumulative List of Changes in Plan Qualification Requirements (2014 Cumulative List) described in section 4 of Rev. Proc. 2007–44… IRCNoticesDec 22, 2014related by meaning
…or a wife, is unconstitutional because it violates the principles of equal protection. (2013 C. L.) Rev. Rul. 2013–17, 2013–38 I.R.B. 201, provides that for Federal tax purposes, the terms “spouse,” “husband and wife,” “husband,” and “wife” include an individual married to a person of the same sex if the individuals ar…
IRCCourt RulingsAug 22, 1994
…the extent the reserve does not exceed the amount that could be accumulated under the principles of Rev. Ruis. 69-382, 1969[ — 2] C.B. 28, and 73-599, 1973-2 C.B. 40. * * * [H. Conf. Rept. 98-861 (1984), 1984-3 C.B. (Vol. 2) 1, 417.]
This quote from the legislative history is relevant for two reasons. First, the confer…
Rev. Rul. 2004-12 — Plan qualification; rollovers. This ruling describes a situation where an eligible retirement plan separately accounts for amounts attributable to rollover con… IRCRevenue RulingsFeb 17, 2004related by meaning
…es and between § 457 eligible governmental plans.
DRAFTING INFORMATION The principal author of this revenue ruling is Roger Kuehnle of the Employee Plans, Tax Exempt and Government Entities Division. For further information regarding this revenue ruling, please contact Employee Plans’ taxpayer assistance telephone serv…
IRCPrivate Letter RulingsDec 14, 2018related by meaning
l revoke or modify a letter ruling and apply the revocation
retroactively if there has been a misstatement or omission of controlling facts; the facts at the time of the transaction are materially different from t he controlling facts on which
the ruling was based; or, in the case of a transaction involving a continuin…
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…
IRCCourt RulingsJun 14, 2012related by meaning
ause, petitioners must show that the assessment of the penalties is so
harsh and oppressive as to transgress the constitutional limitation: See, e.g., McGehee Family Clinic v. Commissioner, T.C.:Memo. 2010-202. The penalty
structure of section 6662A does not do so
Petitioners also contend that their due process rights …
IRCCourt RulingsJun 9, 1977related by meaning
ring trust was valid and of full force and effect. Cf. Precision Industries, Inc. v. Commissioner, 64 T.C. at 907. Moreover, it is irrelevant that Mr. Crist did not reduce his acquiescence to a written form; such an irregularity does not invalidate the authorization in these circumstances. Armstrong Manors v. Burris, 1…
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…
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,…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCCourt RulingsApr 11, 2012related by meaning
…ll as general counsel memoranda published in pre-1955
volumes of the Cumulative Bulletin); Internal Revenue Service
information or press releases; and notices, announcements and other
administrative pronouncements published by the Service in the
Internal Revenue Bulletin. * * *
In 1999 when Dr. and Mrs. White and Dioge…
IRCPrivate Letter RulingsMar 16, 2018related by meaning
Internal Revenue Service Department of the Treasury
Wa shington, DC 20224
Number: 201811008
Release Date: 3/16/2018
Index Number: 414.08-00
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