Transcription of Internal Revenue Service Department of the Treasury
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Internal Revenue ServiceNumber: 200130015 Release Date: 7/27/2001 Index Number: Department of the TreasuryWashington, DC 20224 Person to Contact: Telephone Number: Refer Reply To:PLR-128287-00/CC:TEGE:EB:ECDate:April 26, 2001 X= Plan= Employees = This is in response to your request for a ruling for X, a municipality, regarding thecashout of future vacation leave under the Plan by employees of X.
Section 451(a) of the Internal Revenue Code and section 1.451-1(a) of the Income Tax Regulations provide that an item of gross income is includible in gross income in the taxable year in which it is actually or constructively received by a taxpayer using the cash receipts and disbursements method of accounting. Under section
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