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61. 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 …
62. 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…
63. 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…
64. 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…
65. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    …ations regarding foreign legal restrictions. 189 To eval uate the merits of this contention we will review the various administrative pronouncements made by the Treasury Department from 1986 to 1994. We begin with the 1988 White Paper, which was the comprehensive Treasury Department and IRS study of section 482 request…
66. 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…