Search the Pension Law Library

61. PLR 201626003 — Exceptions
    IRCPrivate Letter RulingsJun 24, 2016
    …l the assets have been distribu ted to participants in accordance with the terms of the plan. Under Revenue Ruling 79-237, 1979-2 C.B. 190 (Rev. Rul. 79-237), once applicable, the minimum funding standards described in section 412 apply to a pension plan through the date of its termination. Rev. Rul. 79-237 defines the…
62. 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…
63. 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 …
64. PLR 201515001 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsApr 10, 2015
    … Service applied these general tax ownership principles in a series of “investor con trol” rulings. 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 …
65. Rev. Proc. 2017-57 — This revenue procedure updates Rev. Proc. 2000–41 to take into account the enactment of subsequent legislation. This revenue procedure sets forth the procedure…
    IRCRevenue ProceduresOct 30, 2017related by meaning
    …the use of the class ruling, or decline to issue a class ruling. SECTION 6. REQUESTING APPROVAL FOR REVOCATION OF AN INTEREST RATE ELECTION
66. 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…
67. 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…
68. 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…
69. 82 T.C. 869; 82 T.C. No. 67 — Winger's Dep't Store, Inc. v. Commissioner
    IRCCourt RulingsJun 4, 1984related by meaning
    … Nor, to the best of our knowledge, has any other court done so. Respondent would have us hold that Rev. Rul. 69-494 acquired the force of law when ERISA was enacted. We need not go so far and conclude that, under the facts of this case, the trust did not operate for the exclusive benefit of employees within the meanin…
70. PLR 199910006 — Deferred Compensation
    IRCPrivate Letter RulingsMar 12, 1999
    …he taxpayer's control of its receipt is subject to substantial limitations or restrictions. 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 se…
71. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980related by meaning
    ess., 1962-3 C.B. 261, 268-269. All of these rulings have been declared obsolete. Rev. Rul. 72-488, 1972-2 C.B. 649; Rev. Rul. 72-92, 1972-1 C.B. 408. Although petitioner does not directly argue that the regulation is void, it would, in effect, have us invalidate all of the regulations mentioned above. Because this Cou…