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64 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. PLR 199905003 — Nonqualified Annuities
    IRCPrivate Letter RulingsFeb 5, 1999
    ions. Various revenue rulings have considered the tax consequences of nonqualified deferred compensation arrangements. Rev. Rul. 60-31, Situations 1-3 , 1960-1 C.B. 174, holds that a mere promise to pay, not represented by notes or secured in any way, does not constitute receipt of income within the meaning of the cash…
  2. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004
    …t its method of accounting for (accelerating) deductions for employer contributions is described in Rev. Rul. 2002-46, not Rev. Rul. 90-105. Therefore, IDR No. 10, citing Rev. Rul. 2002-46, placed Taxpayer ‘s method of accounting under consideration. Taxpayer contends that it applied for an automatic method change on J…
  3. 73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner
    IRCCourt RulingsOct 30, 1979related by meaning
    … We sustain respondent's determination. Respondent is authorized to determine the extent to which a revocation of a determination letter will be applied without retroactive effect. Sec. 7805(b); sec. 301.7805-1(b), Proced. & Admin. Regs. 10 We must uphold the retroactive revocation in the instant case unless respondent…
  4. PLR 199912002 — Year of Deduction
    IRCPrivate Letter RulingsMar 26, 1999
    ion arrangements. Rev. Rul. 60-31, Situations 1-3 , 1960-1 C.B. 174, holds that a mere promise to pay, not represented by notes or secured in any way, does not constitute receipt of income within the meaning of the cash receipts and disbursements method of accounting. See also, Rev. Rul. 69-650, 1969-2 C.B. 106, and Re…