Internal Revenue Bulletins  

December 19, 1994

Internal Revenue Bulletin No. 1994-51

There are no links to the official documents for the years 1989 through 1995. The information below can only be used as help for further research, as there is not enough information here to rely on for official guidance. For that you need to obtain a copy of the complete document.


Rev. Rul. 94-77
Severance pay as business expenses. The Supreme Court's decision in INDOPCO, Inc., does not affect the treatment of severance payments, made by a taxpayer to its employees, as business expenses that are generally deductible under section 162 of the Code.

Rev. Rul. 94-78
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning January 1, 1995, will be 8 percent for overpayments, 9 percent for underpayments, and 11 percent for large corporate underpayments.

Rev. Rul. 94-79
Classification of Connecticut limited liability company. Because of the flexibility accorded by the Connecticut Limited Liability Company Act, a Connecticut limited liability company may be classified as a partnership or an association taxable as a corporation depending upon the provisions adopted in the limited liability company's articles of organization or operating agreement.

Proposed regulations under section 83 of the Code relating to deductions for transfers of property.

Amendments to proposed regulations under section 162 of the Code relating to the disallowance of deductions for employee remuneration in excess of $1,000,000.

Announcement 94-142
Star Trek Association of Towson, Inc., Towson, MD, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.


Notice 94-103
Guidance is provided on the effect of the Family and Medical Leave Act of 1993, P.L. 103-3, on the COBRA continuation coverage requirements for group health plans under section 4980B of the Code.

Announcement 94-143
Petitions have been filed to add cyclododecanol, 1,5,9-cyclododecatriene, and adiponitrile to the list of taxable substances in section 4672(a)(3) of the Code.


Rev. Proc. 94-74
Penalties; substantial understatement. Guidance is provided concerning when information shown on a return in accordance with the applicable forms and instructions will be adequate disclosure for purposes of reducing an understatement of income tax under section 6662(d) of the Code.

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