IRCCourt RulingsSep 30, 1985related by meaning
… employers has nothing to do with the issue before the Court. As in Ridenour, petitioner also cites Rev. Rul. 69-647, 1969-2 C.B. 100, to support his position. In Rev. Rul. 69-647, the Commissioner ruled that an employee who retired from full-time employment but continued to provide advisory opinions on an irregular ba…
Notice 2012-6 — This notice extends and expands the transition relief provided under Rev. Rul. 2011-1, 2011-2 I.R.B. 251, and Rev. Rul. 2008-40, 2008-2 C.B. 166, for certain g… IRCNoticesJan 17, 2012
(24) of the Internal Revenue Code (Code) (§ 401(a)(24) plans) to be amended to satisfy the applicable requirements of Rev. Rul. 2011-1.
II. BACKGROUND Rev. Rul. 81-100, 1981-1 C.B. 326, provides that qualified retirement plans and individual retirement accounts are permitted to pool their assets for investment purposes…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024★ strong match
…ERMINATION LETTERS WILL NOT BE ISSUED UNTIL THE SERVICE RESOLVES THE ISSUE THROUGH PUBLICATION OF A REVENUE RULING, A REVENUE PROCEDURE, REGULATIONS, OR OTHERWISE
.01 Specific Questions and Problems.
(1) Sections 302 and 304.—Distributions in Redemption of Stock; Redemption Through Use of Related Corporations.—Treatmen…
Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government … IRCRevenue ProceduresJan 3, 2017★ strong match
…:
(1) § 72 (involving computation of the exclusion ratio only);
(2) Changes in funding methods (see Rev. Proc. 2000–41, 2000–2 C.B. 371) and actuarial assumptions under § 412, 430, 431 or 433;
(3) Waiver of the liquidity shortfall (as that term is defined in § 430(j)(4)) excise tax under § 4971(f)(4);
(4) Waiver of the…
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007★ strong match
ties), Internal Revenue Service. However, personnel from other offices of the IRS and Treasury Department participated in their development.
* * * * * [1] See Rev. Rul. 2005-55, 2005-2 C.B. 284, and Rev. Rul. 2005-24, 2005-1 C.B. 892, see §601.601(d)(2)(ii)(b) (section 105(b) exclusion only applicable to reimbursements…
Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U… IRCNoticesApr 21, 2014★ strong match
…nconstitutional because it violates Fifth Amendment principles. Subsequent to the Windsor decision, Rev. Rul. 2013–17 held the following: (1) For Federal tax purposes, the terms “spouse,” “husband and wife,” “husband,” and “wife” include an individual married to a person of the same sex if the individuals are lawfully …
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006★ strong match
…oss income, if there is no intermediary private foundation distributing the grants, as there was in Rev. Proc. 76-47, 1976-2 C.B. 670.
(15)
Rev. Rul. 2011-1 — This ruling modifies the rules for group trusts described in Rev. Rul. 81-100, 1981-1 C.B. 326, as clarified and modified by Rev. Rul. 2004-67, 2004-2 C.B. 28.… IRCRevenue RulingsModified Jan 10, 2011
by reason of section 833(c)(5) of the Code. Rev. Proc. 2008-52 modified. Notice 2010-79 clarified and modified.
Rev. Proc. 2011-12 Rev. Proc. 2011-12 Cost-of-living adjustments for 2011. This procedure sets forth the 2011 cost-of-living adjustments to certain items due to inflation as required under various provisions…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005★ strong match
…oss income, if there is no intermediary private foundation distributing the grants, as there was in Rev. Proc. 76-47, 1976-2 C.B. 670.
(13)
IRCCourt RulingsMar 26, 1979related by meaning
…s. * » * ”
(Emphasis added.)
See also S. Rept. 830, n. 6 supra. It is not without significance that Rev. Rul. 67-258 was not issued until several years after Congress had enacted sec. 72(m) specifically making taxable loans received by owner-employees. See p. 1056 supra. In this context, it appears that respondent has …
PLR 202417010 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan IRCPrivate Letter RulingsApr 26, 2024
t cause
Taxpayer to fail to qualify as an 81-100 group trust within the meaning of Rev. Rul.
2011-1.
LAW AND ANALYSIS
Rev. Rul. 81-100, as modified,
1 provides that certain retiree benefit plans and other
arrangements are permitted to pool their assets for investment purposes in an “81-100
group trust” if certain speci…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968
…ch congressional intent in the legislative history of the section. H.R. 9893, 84th Cong., 2d Sess. (1956); H. Rept. No. 1890, 84th Cong., 2d Sess. (1956); S. Rept. No. 2364, 84th Cong., 2d Sess. (1956); H. Rept. No. 2641, 84th Cong., 2d Sess. (1956); H.R. 12270, 84th Cong., 2d Sess. (1956); S. Rept. No. 2775, 84th Cong…
IRCCourt RulingsApr 18, 1960
…s of the compensation formula for services performed by the petitioner during the year 1955. During 1956 the Lancaster Hospital continued to deposit checks in the savings account, based upon petitioner’s percentage of X-ray charges. The balance in such account on December 28, 1956, was $8,795.63, of which $8,794.37 was…
Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru… IRCRevenue ProceduresJan 2, 2020★ strong match
…:
(1) § 72 (involving computation of the exclusion ratio only);
(2) Changes in funding methods (see Rev. Proc. 2017–57, 2017–44 I.R.B. 474) and actuarial assumptions under § 412, 430, 431 or 433;
(3) Waiver of the liquidity shortfall (as that term is defined in § 430(j)(4)) excise tax under § 4971(f)(4);
(4) Waiver of …
IRCCourt RulingsMay 27, 2010
…tar Plan, the applicable Federal rate was 3 .89 percent for a short-term loan compounded annually . Rev . Rul . 2005-66, 2005-2
C .B . 686 . Mid- and long-term rates were higher . Id . In March
2006, when Mogelefsky withdrew from Benistar Plan, the applicable
Federal rate .was 4 .58 percent for a short-term loan compou…
Rev. Rul. 2014-9 — This revenue ruling provides simplified safe harbor due diligence procedures a plan administrator may use in order to be deemed to have reasonably concluded th… IRCRevenue RulingsApr 21, 2014related by meaning
…the decision in United States v. Windsor, 570 U.S. ___, 133 S. Ct. 2675 (2013), and the holdings of Rev. Rul. 2013–17, 2013–38 I.R.B. 201 (Sept. 16, 2013), to retirement plans qualified under section 401(a) of the Internal Revenue Code (Code). Rev. Rul. 2013–17 is amplified.
IRCCourt RulingsJun 14, 1982related by meaning
…oduct of an erroneous computation in the statutory notice of deficiency and that should respondent prevail, the petitioners are only liable for a deficiency of $955.
Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as in effect during the year at issue.
During the year before …
Rev. Rul. 2004-67 — Group or pooled trusts; participation; tax-exempt status, model language. This ruling provides that a governmental section 457(b) plan may invest in a second t… IRCRevenue RulingsJul 12, 2004related by meaning
…mination letter issued to it prior to July 12, 2004, regarding eligibility of its group trust under Rev. Rul. 81-100 will not lose its right to rely on its determination letter merely because it adopts Model Amendment 1 set forth above in this revenue ruling on a word-for-word basis (or adopts an amendment that is subs…
Rev. Rul. 2009-18 — Tax-sheltered annuity contracts. This ruling notes that a number of guidance documents had become outdated due to numerous intervening statutory revisions enac… IRCRevenue RulingsJul 6, 2009related by meaning
…unting or taxable year on behalf of a foreign corporation by its controlling domestic shareholders.
Rev. Proc. 2009-31 Rev. Proc. 2009-31
This procedure provides guidance regarding the granting or revocation of consent to treat intercompany transactions on a separate entity basis under regulations section 1.1502-13(e)(…
PLR 202524006 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan IRCPrivate Letter RulingsJun 13, 2025
…“group t rust retiree benefit plans,” are qualified retirement plans under § 401(a) of the Internal Revenue Code (Code); governmental retiree benefit
plans under § 401(a)(24); certain custodial accounts under § 403(b)(7); retirement
income accounts under § 403(b)(9 ); IRAs that are exempt under § 408(e); eligible
gover…