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81. PLR 202429010 — Tax on Reversion of Qualified Plan Assets to Employer
    IRCPrivate Letter RulingsJul 19, 2024
    980 of the Internal Revenue Code (Code) of the direct transfer of all of the remaining assets of Plan A, a qualified defined benefit plan sponsored by Taxpayer that has been terminated, to Plans B and C, two qualified profit-sharing plans sponsored by Taxpayer. Facts Taxpayer is a publicly traded company that, along wi…
82. PLR 202242006 — Tax on Reversion of Qualified Plan Assets to Employer
    IRCPrivate Letter RulingsOct 21, 2022
    …i od under the same procedure. This method of allocation complies with the requirements of section 4980(d)(2)(C)(i). Therefore, in this case, this method of crediting of the amounts transferred from Cash Balance Plan to suspense accounts in each of the recei ving plans, and this method of allocation of the assets in th…
83. PLR 201626005 — Exceptions
    IRCPrivate Letter RulingsJun 24, 2016
    er section 4980(d)(1), the excise tax under section 4980 shall be increased to 50 percent with respect to an employer revers ion from a qualified plan unless the employer either establishes or maintains a “qualified replacement plan”, or the plan provides for certain benefit increases which take effect on the terminati…
84. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    E. France from Jos. A. Bank Clothiers, Inc., and the parties stipulate that the correct amount for taxable year 2000 is $4,525. Based on this, we hold that petitioners’ taxable year 2000 wage income is to be reduced in the amount of $737. Issue 3. Taxable Year 1997 Respondent issued a notice of deficiency for taxable y…
85. PLR 202348005 — Tax on Reversion of Qualified Plan Assets to Employer
    IRCPrivate Letter RulingsDec 1, 2023
    the termination be active participants in the replacement plan. Section 4980(d)(2)(B) requires that a direct transfer from the terminated plan to the replacement plan be made before any employer reversion, and that the transfer be an amount equal to the excess (if any) of (i) 25 percent of the maximum amount which the…
86. 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, 2007related by meaning
    2 Announcement 2007-52 A list is provided of organizations now classified as private foundations. ADMINISTRATIVE Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
87. PLR 202111005 — Exceptions
    IRCPrivate Letter RulingsMar 19, 2021
    …d that any amount that the employer received would be subject to the 20 percent excise tax under § 4980(a) and would be includible in income unde r § 61. Under § 501(a), an organization described in § 401(a) (that is, a trust which is part of a qualified pension, profit-sharing or stock bonus plan) is generally exempt …
88. PLR 201626003 — Exceptions
    IRCPrivate Letter RulingsJun 24, 2016
    …property received (directly or indirectly) by the employer from the qualified plan. Under section 4 980(d)(2), a “qualified replacement plan” is a qualified plan established or maintained by the employer in connection with a qualified plan termination, which satisfies the participation, asset transfer, and allocation r…
89. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
90. 78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans
    IRCFinal Rules (FR)Dec 26, 2013
    …uding both HPML and non-HPML refinances). According to public data recently reported by FHFA, 1,803,980 streamlined refinance loans occurred under Fannie Mae or Freddie Mac streamlined refinance programs. See FHFA Refinance Report for February 2013, available at
91. 78 FR 48548 — Appraisals for Higher-Priced Mortgage Loans-Supplemental Proposal
    IRCProposed Rules (FR)Proposed Aug 8, 2013
    …uding both HPML and non-HPML refinances). According to public data recently reported by FHFA, 1,803,980 streamlined refinance loans occurred under Fannie Mae or Freddie Mac streamlined refinance programs. See FHFA Refinance Report for February 2013, available at http://www.fhfa.gov/​webfiles/​25164/​Feb13RefiReportFina…
92. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020related by meaning
    little more than guesswork and failed to satisfy the strict substantiation requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section 274(d). Cons…