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Rev. Rul. 2003-97 provides guidance on whether

SECTION 8. DRAFTING

Internal Revenue Bulletin 2003-34 · 2026-10-03 edition · updated 2026-10-04 · United States

INFORMATION

The principal author of this procedure is Erinn Madden of the Office of Chief Counsel of the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities. However, other personnel from the IRS and Treasury Department participated in its development. For further information regarding this revenue procedure, contact Ms. Madden (202) 622–6030 (not a toll-free call).

This value is then used to re-determine the portion of the payment that is contingent on the change in ownership under § 1.280G–1, Q/A–24(c). This amount is $350,800, the sum of (1) $113,900 (the amount by which the value of the payment, $1,030,000, exceeds the present value of the payment, determined to be $916,100), and (2) $236,900 (23 times 1% times $1,030,000). Using the base amount initially allocated to this payment, $50,000, the portion of the payment that is an excess parachute payment is $300,800, and the excise tax is $60,160. E is permitted to file an amended return for 2005 using the revised calculations as a basis for claiming a refund of $4,456.

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▸Contents — Internal Revenue Bulletin 2003-34
Internal Revenue Bulletin 2003-34

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