However, under Rev. Rul.
2015-9, the characterization as a Sec.
At the time Rev. Rul.
69-136 was issued, there was in fact a limited exemption for FICA and FUTA tax purposes for stand-by payments made to employees who had attained age 62, if the employee did not work for the employer during the period, if the employment relationship continued to exist, and if the pay was other than vacation or sick pay.
2002-62 allows taxpayers great leeway in fashioning distributions to avoid the 10-percent additional tax and still withdraw funds from their IRAs to meet their financial needs.
Happily for tax professionals, Rev. Rul.
2008-25 neatly ties together the three rulings mentioned above and answers the question left unanswered in Rev.
The good news is that Rev. Rul.
2002-22 seems to have overturned the IRS rationale found in Field Service Advise 200005006 issued in November 1999.
In explaining the application of those exclusions, the Preamble helpfully points out that the determination of their application depends on deductibility under section 162(a) of the Code and, moreover, that Rev. Rul.
99-7(21) addresses the circumstances under which daily transportation expenses, including parking, incurred by a taxpayer in going between home and a temporary work location are deductible under section 162(a).(22)
Notwithstanding the holding of Rev. Rul.
73-526, in Rev.
We recognize that there are a number of issues in the environmental cleanup area that remain unresolved despite the issuance of Rev. Rul.
12, 2005 (i.e., during the period when the Service made relief available to cases falling under Rev. Rul.
Is Rev. Rul.
96-62 a lump of coal the IRS placed in taxpayers' stockings on December 23rd or is it a nicely wrapped present?
The TAMs followed a very similar logic to Rev. Rul.
2005-48, and concluded that income is recognized for AMT purposes on the exercise date (assuming it is at least six months after the grant date).
Taxpayers are currently incurring expenses in many other areas that we believe warrant public guidance similar to that promulgated Rev. Rul.