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66 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. 74 T.C. 1029 — E. F. Higgins & Co. v. Commissioner
    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…
  2. 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,…
  3. PLR 201850011 — Separate Lines of Business and Operating Units
    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…
  4. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007
    INCOME TAX Rev. Rul. 2007-34 Rev. Rul. 2007-34 LIFO; price indexes; department stores. The March 2007 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 referen…
  5. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    Rev. Rul. 69-421 (Part 2(j)(l)), 1969-2 C.B. 59, 64, sets forth respondent’s position rejecting the prior service of self-employed individuals — partners and sole proprietors — for both prior service benefits and eligibility requirements. He, therefore, concludes that the prior services of a sole proprietor cannot be c…
  6. Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul…
    IRCNoticesDec 27, 2005
    …)(v) of the Code and the applicable mortality table under § 417(e)(3)(A)(ii)(I) of the Code. (New). Rev. Rul. 2002-42, 2002-1 C.B. 76, provides guidance with respect to a situation where a money purchase pension plan is merged or converted into a profit sharing plan. Rev. Proc. 2002-21, 2002-1 C.B. 911, provides guidan…