Chief Counsel's Written Determinations Issued from 200025000 to 200029999

Taxpayer-specific rulings or determinations are written memoranda furnished by the IRS National Office in response to requests by taxpayers under published annual guidelines. Technical advice memoranda are written memoranda furnished by the National Office of the IRS upon request of a district director or chief appeals officer pursuant to annual review procedures. Chief Counsel advice are written advice or instructions prepared by the Office of Chief Counsel and issued to field or service center employees of the IRS or Office of Chief Counsel.

It is important to note that pursuant to 26 USC § 6110(j)(3), such items cannot be used or cited as precedent.

200029056(PDF, 242K)	4/25/2000
This is in response to a ruling request dated February 9, 2000, concerning the pick up of certain employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code.
200029055(PDF, 203K)	9/27/2001
This is in response to a letter dated November 5, 1999, as supplemented by correspondence dated February 1,2000, submitted on your behalf by your authorized representative requesting rulings under § 5 12(e)( 1) and (e)(3) of the Internal Revenue Code. The following facts and representations were submitted in connection with your request.
200029054(PDF, 32K)	7/21/2000
Issue: A taxpayer closes restaurants that are no longer economically viable and offers them for sale. May the taxpayer deduct losses upon a restaurant's closure if the taxpayer has not sold the restaurant by year-end?
200029053(PDF, 19K)	7/21/2000
November 17, 1999, in which rulings were requested as to the federal income tax consequences of a proposed transaction.
200029052(PDF, 7K)	7/21/2000
October 19, 1999 letter and subsequent correspondence that X's authorized representative submitted on behalf of X concerning relief under § 1362(b)(5) of the
200029051(PDF, 18K)	7/21/2000
November 3, 1999, and other, previous and subsequent correspondence, in which he requested on your behalf certain rulings regarding the proper federal income tax treatment, including any reporting and/or withholding obligations, for certain tuition
200029050(PDF, 10K)	7/21/2000
January 4, 2000, requesting a ruling that the restrictions placed on Company's nonvoting common stock by an employment agreement (the "Agreement") will not cause Company to have a second class of stock under § 1361(b)(1)(D) of the Internal Revenue Code.
200029049(PDF, 12K)	7/21/2000
December 10, 1999 requesting that we rule on a significant federal income tax subissue present in a proposed transaction. See § 3.01(27) of Rev. Proc. 2000-3, 2000-1 I.R.B. 103, 107.
200029048(PDF, 19K)	7/21/2000
February 8, 2000, requesting rulings that Taxpayer's disclaimer with respect to a fractional share of Taxpayer's interest in Trust principal constitutes a valid disclaimer under § 25.2511-1 of the Gift Tax Regulations and does not constitute a gift under § 2501 of the Internal Revenue Code.
200029047(PDF, 19K)	7/21/2000
December 21, 1999, requesting, on behalf of the taxpayers identified above, an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200029046(PDF, 25K)	7/21/2000
Pursuant to § 8.07(2)(b) of Revenue Procedure 2000-1, 2000-1 I.R.B. 4, at 83-4, we are writing to inform you that a taxpayer located within your district has withdrawn a request for a private letter ruling.
200029045(PDF, 7K)	7/21/2000
February 18, 2000, and subsequent correspondence, submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200029044(PDF, 14K)	7/21/2000
February 7, 2000, submitted on behalf of Taxpayer, requesting a private letter ruling regarding the application of § 42(j) of the Internal Revenue Code to a proposed transfer of bare legal title to certain real property owned by Taxpayer to Corp.
200029043(PDF, 7K)	7/21/2000
January 17, 2000 on behalf of Company, requesting permission for Company to reelect S corporation status under § 1362(g) of the Internal Revenue Code.
200029042(PDF, 19K)	7/21/2000
December 13, 1999, submitted by your authorized representative requesting rulings under § 280G of the Internal Revenue Code.
200029041(PDF, 20K)	7/21/2000
March 14, 2000, on behalf of the above taxpayers, requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Partner A (as the United States shareholder of Purchaser, the foreign purchasing corporation) to file an election under § 338(g) of the Internal Revenue Code and §§ 1.338-1(d) and 1.338-1(g) of the Income Tax Regulations with respect to Purchaser's acquisition of the stock of Foreign Sub (sometimes hereinafter referred to as the "Election") on Date A.
200029040(PDF, 15K)	7/21/2000
December 8, 1999, request for rulings under §§ 305 and 306 of the Internal Revenue Code.
200029039(PDF, 40K)	7/21/2000
August 27, 1999, and subsequent correspondence, requesting a ruling that Authority is a political subdivision of Tribe within the meaning of §§ 7871(d) and 7701(a)(40) of the Internal Revenue Code.
200029038(PDF, 9K)	7/21/2000
December 22, 1999, requesting that we supplement our ruling letter dated December 9, 1999, Control Number PLR-106450-99 (published as PLR 200010028) ("the Prior Ruling Letter"). The Prior Ruling Letter concerned certain federal income tax consequences of a corporate separation under § 355 of the Internal Revenue Code.
200029037(PDF, 45K)	7/21/2000
March 31, 1999 request for rulings on certain federal income tax consequences of a proposed transaction.
200029036(PDF, 12K)	7/21/2000
February 29, 2000, on behalf of Fund by Company 1, requesting an extension of time pursuant to § 301.9100-1(a) of the Procedure and Administration Regulations for Fund to make an election under § 855(a) of the Internal Revenue Code for Year 1.
200029035(PDF, 16K)	7/21/2000
September 13, 1999, requesting rulings under § 280G and 4999 of the Internal Revenue Code. Specifically you requested a ruling whether, under the facts outlined below, there will be a change in the ownership or effective control of Target, or in the change in the ownership of a substantial portion of the assets of Target within the meaning of § 280G(b)(2) of the Code.
200029034(PDF, 61K)	7/21/2000
Issues: (1) Whether income (including warranty and repair income) received by Corp A with respect to export sales of the Product to Purchaser under contracts acquired from Corp B, an unrelated entity, constitutes foreign trading gross receipts of Corp A within the meaning of Internal Revenue Code § 924, where some sales of the Product had been shipped to the Purchaser by Corp B prior to Corp A's acquisition of the contracts. (2) Whether Corp A may use the administrative pricing rules of I.R.C. § 925(a) in determining commissions payable by Corp A to Corp A-FSC with respect to foreign trading gross receipts from export sales of the Product to the Purchaser.
200029033(PDF, 24K)	7/21/2000
October 11, 1999, and subsequent correspondence submitted by you as X's authorized representative on behalf of X, requesting rulings under §§ 671 and 4941 of the Internal Revenue Code.
200029032(PDF, 32K)	7/21/2000
December 7, 1999, in which you request rulings as to the federal tax consequences of a proposed transaction. Additional information was received in subsequent submissions.
200029031(PDF, 10K)	7/21/2000
September 15, 1999, and subsequent correspondence, submitted on behalf of A and B, requesting a ruling that Trust will not be disqualified as a charitable remainder unitrust under § 664(d)(2) of the Internal Revenue Code.
200029030(PDF, 148K)	7/21/2000
Contacts by field offices about various Federal Insurance Contributions Act ("FICA") refund claims that have been filed around the country. You in turn contacted this office for advice. Because this advice will be distributed to the field offices, it constitutes conduit Chief Counsel Advice subject to disclosure under § 6110 of the Internal Revenue Code.
200029029(PDF, 18K)	7/21/2000
November 1, 1999 on behalf of the above taxpayers, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200029028(PDF, 8K)	7/21/2000
February 8, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200029027(PDF, 8K)	7/21/2000
March 3,2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200029026(PDF, 10K)	7/21/2000
December 29, 1999, submitted on behalf of Partnership and Agency, requesting an extension of time to make an election under § 42(g)(1) of the Internal Revenue Code pursuant to § 301.9100-1 of the Procedure and Administration Regulations.
200029025(PDF, 22K)	7/21/2000
November 1, 1999, on behalf of the above taxpayers, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Additional information was submitted on February 3, 2000 and March 2, 2000.
200029024(PDF, 19K)	7/21/2000
June 28, 1999, on behalf of the above taxpayers, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200029023(PDF, 16K)	7/21/2000
November 1, 1999 on behalf of the above taxpayers, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200029022(PDF, 25K)	7/21/2000
March 15, 1999, and additional information submitted on behalf of the Taxpayer by its authorized representative. The request is for a revised schedule of ruling amounts under the mandatory review requirement of § 1.468A-3(i)(1)(iii)(A)(3) of the Income Tax Regulations, as the ruling amounts set forth in the previous ruling letter expired after calendar year.
200029021(PDF, 25K)	7/21/2000
March 15, 1999, and additional information submitted on behalf of the Taxpayer by its authorized representative. The request is for a revised schedule of ruling amounts under the mandatory review requirement of § 1.468A-3(i)(1)(iii)(A)(3) of the Income Tax Regulations, as the ruling amounts set forth in the previous ruling letter expired after calendar year.
200029020(PDF, 20K)	7/21/2000
November 5, l999, submitted by the authorized representative as to whether § 104 of the Internal Revenue Code allows a decedent's estate ("B") to exclude a settlement of a wrongful death claim from federal income tax. You are the executor of B.
200029019(PDF, 8K)	7/21/2000
In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer, requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending ________, to a taxable year ending ________, effective ________.
200029018(PDF, 12K)	7/21/2000
Whether interest paid by the Association on a secured loan obtained by the Association to demolish and restore a portion of the common elements of the Association is deductible by Taxpayer under § 163(h), subject to (1) any other limitations on the deductibility of qualified residence interest, (2) the requirement that the loan is secured by the taxpayer's qualified residence, and (3) the requirement that the taxpayer's residence is part of the Association.
200029017(PDF, 10K)	7/21/2000
July 9, 1999, and subsequent correspondence, requesting a ruling under § 29 of the Internal Revenue Code.
200029016(PDF, 7K)	7/21/2000
November 19, 1999, and subsequent correspondence, written on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200029015(PDF, 10K)	7/21/2000
For the tax year ending on x, Taxpayer elected to determine its credit for increasing research activities under the alternate incremental research credit rules of § 41(c)(4).
200029014(PDF, 27K)	7/21/2000
August 30, 1999, requesting, on behalf of the above taxpayers, an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to make an election.
200029013(PDF, 55K)	7/21/2000
Issue: Under the rules of Internal Revenue Code § 83, was Company entitled to a compensation expense deduction as a result of its executives' exercise of an option to purchase Company shares, or was that option earlier converted into a contract obligating the executives to purchase the shares, which would have caused the § 83 event to occur when the executives' contractual rights became substantially vested?1
200029012(PDF, 17K)	7/21/2000
June 7, 1999 letter, on behalf of the above taxpayers, requesting an extension of time, under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations, to file an election.
200029011(PDF, 106K)	7/21/2000
Issues: (1) Whether the accounting method change consent letter granted Taxpayer permission to compute Taxpayer - FSC's commission using the joint cost accounting method described therein, or whether the "no opinion" clause in the consent letter delegated authority to the District Director to determine the appropriateness of the described joint cost accounting method for computing the amount allowable as a foreign sales corporation (FSC) commission. (2) Whether Taxpayer's method of allocating joint production costs to categorys satisfies the requirements of § 1.471-7 of the Income Tax Regulations, or whether Taxpayer's joint production costs must be further allocated among detailed categorys to satisfy the requirement of § 1.471-7 that the joint cost allocation "bear a reasonable relation to the selling values of the different kinds, sizes, or grades of product." (3) Whether § 1.471-7 requires that Taxpayer divide its export products and similar domestic products into separate categories because the disparate selling prices commanded by export and domestic products result from differences in their size, kind, or grade. (4) Whether § 1.925(a)-1T(c)(6)(iii) of the temporary regulations imposes an additional standard for the allocation of production costs. If so, whether Taxpayer's allocation method satisfies that standard. (5) Whether the accounting method change consent letter may be retroactively modified or revoked if it is determined that Taxpayer's method of allocating joint production costs does not satisfy the requirements of § 1.471-7 or § 1.925(a)-1T(c)(6)(iii).
200029010(PDF, 34K)	7/21/2000
Issue: Whether Taxpayer's operating subsidiaries are entitled to deductions for "insurance" premiums paid to C pursuant to a brother-sister captive insurance arrangement.
200029009(PDF, 30K)	7/21/2000
Requesting for assistance in formulating procedures for the Collection Division for working offer-in-compromise cases during the time in which the Office of Appeals ("Appeals") has jurisdiction over a Collection Due Process ("CDP") proceeding.
200029008(PDF, 36K)	7/21/2000
Issues: (1) Whether a Service employee conducting an EIC due diligence audit on a return preparer is required to provide the return preparer with a summons for any information required to conduct the audit. (2) May a return preparer rely on the tax advice privilege under § 7525 of the Code in refusing to provide information required to conduct an EIC due diligence audit? (3) How should a return preparer treat conflicting information received from two taxpayers with regard to filing returns or claims for refund claiming the EIC?
200029007(PDF, 11K)	7/21/2000
Issue: Whether a taxpayer has made a timely refund claim where the refund claim was filed more than three years after the taxpayer's return was filed and the Service applied the taxpayer's partial, undesignated payments made within two years of the refund claim to penalties and interest. If the refund claim is untimely, what are the remedies available to the Service for recovery of an erroneous abatement based on the untimely refund claim.
200029006(PDF, 36K)	7/21/2000
November 29, 1999, and supplementary submissions requesting on behalf of Taxpayer certain rulings regarding the treatment of sub-accounts of the Separate Account that invest in portfolios ("Portfolios") of Fund A, Fund B, and Fund C (collectively referred to as the "Funds").
200029005(PDF, 26K)	7/21/2000
January 4, 2000, requesting a ruling that the restrictions placed on Company's nonvoting common stock by an employment agreement (the "Agreement") will not cause Company to have a second class of stock under § 1361(b)(1)(D) of the Internal Revenue Code.
200029004(PDF, 31K)	7/21/2000
Issue: Whether a stipulated decision document in a Tax Court employment status proceeding under § 7436 of the Internal Revenue Code of 1986 may contain settlement terms identifying the agreed amount of taxpayer's employment tax liability in stipulations appearing below the Tax Court judge's signature in the stipulated decision document.
200029002(PDF, 45K)	7/21/2000
Issues: (1) Whether voluntary undesignated payments or involuntary levy payments applied to nontrust fund tax liabilities are protected from avoidance by a chapter 7 trustee by the holding in Begier v. Internal Revenue Service, 496 U.S. 53 (1990), that a voluntary prepetition payment of trust fund taxes is not payment of "property of the debtor."
200029001(PDF, 78K)	7/21/2000
Issues: (1) Whether the non-interest portions of payments to former employees in settlement of a grievance relating to the violation of a collective bargaining agreement by an association of employers are wages subject to the taxes imposed under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA). (2) If the non-interest portions of the settlement payments are wages subject to FICA taxes and FUTA taxes, whether liability for these taxes is based on treating the wages as subject to these taxes in the year paid or in the year to which the payments relate. (3) If the non-interest portions of the settlement payments are wages subject to FICA taxes and FUTA taxes based on the year in which they are paid, what language should a service center use on the Letter 105C in disallowing the claims. (4) If the non-interest portions of the settlement payments are wages subject to FICA and FUTA taxes in the year paid, what action should be taken with respect to recovery of an erroneous refund of FICA taxes paid to the taxpayer.
200028043(PDF, 102K)	9/27/2001
This is in response to your ruling request of January 27, 2000, requesting advance approval of your scholarship program (Program) pursuant to § 4945(g) of the Internal Revenue Code.
200028042(PDF, 181K)	9/27/2001
This is in response to a request for a ruling letter submitted on your behalf by your authorized representative on June 10, 1999, as supplemented by letters dated July 29, 1999, September 21, 1999 and December 14, 15 and 16, 1999. This request concerns the consequences under § 401(k)(4)(B) of the Internal Revenue Code of extending Plan P to additional governmental entities in State A.
200028041(PDF, 425K)	9/27/2001
This is in response to the letter submitted by your authorized representative on your behalf, as supplemented by correspondence, in which you ask for a series of letter rulings under § 401(a)(9) of the Internal Revenue Code.
200028040(PDF, 436K)	9/27/2001
This is in response to the letter submitted by your authorized representative on your behalf, as supplemented by correspondence, in which you ask for a series of letter rulings under § 401(a)(9) of the Internal Revenue Code.
200028039(PDF, 185K)	9/27/2001
This is in reply to the letter dated October 13, 1999, regarding whether the assets of a black lung trust and an escrow account established by A may be used to satisfy your black lung liabilities and those of your subsidiary corporations and to provide accident and health benefits to retired miners who used to work for you and their spouses and dependents.
200028038(PDF, 484K)	9/27/2001
This is in response to M's request for a ruling that supercedes our letter to M dated January 21, 2000. This ruling, as our letter of January 21, 2000 provides certain rulings under § 501(c)(3), 507, 4940, 4941, 4942, 4944, and 4945 of the Internal Revenue Code of 1986 submitted by M's authorized legal representative relating to M's termination and charitable fund agreement with N. This ruling incorporates certain factual corrections on page 2 relating to the terms of the charitable fund agreement.
200028037(PDF, 140K)	9/27/2001
This is in reply to a ruling request dated November 12, 1999, with respect to setting aside additional funds to complete the construction of B and that such set-aside will satisfy the suitability test or § 4942(g)(2)(B)(i) of the Internal Revenue Code.
200028036(PDF, 35K)	7/14/2000
Issue: When a levy payment creates an overpayment to a taxpayer's account (and no balance is due for any other period listed in the levy), may the overpayment be manually refunded, even though more than nine months have elapsed since the date of the levy?
200028035(PDF, 25K)	7/14/2000
Issue: Whether amounts received by a taxpayer for services performed as a juror ("jury fees") are earned income for purposes of the Earned Income Credit (EIC).
200028034(PDF, 31K)	7/14/2000
Issue: May a taxpayer who otherwise met the requirements of § 32 of the Code for a taxable year, but whose claim for the EIC was denied for that year for failure to have an SSN that met the requirements of § 32(m), claim the EIC for the taxable year on an amended federal income tax return, if the taxpayer is issued an SSN that meets the requirements of § 32(m) after the close of the taxable year?
200028033(PDF, 34K)	7/14/2000
Issue: Whether a Form 1040 that reports zeroes on each line and is signed by the taxpayer without any modifications, additions, or deletions to the attestation statement is a return for purposes of § 6501 and 6511.
200028032(PDF, 26K)	7/14/2000
Issues: (1) Whether it is proper for a State, for information reporting requirements under the Internal Revenue Code , to request an EIN from an individual who purports to act as a fiduciary of an estate, when State, engaged in a trade or business, pays income to such individual in an amount of $600 or more in a calendar year. (2) Whether the Internal Revenue Service should issue an EIN to an individual, when such individual requests the EIN for the estate of a decedent, but informs the Service that he or she is not the fiduciary of the estate.
200028031(PDF, 40K)	7/14/2000
Issues: Whether sovereign immunity is a viable defense to the enforcement of income deduction orders that are entered pursuant to § 1325(c) of the Bankruptcy Code against the Service with respect to debtors' future income tax refunds.
200028030(PDF, 74K)	7/14/2000
Issues: (1) What are the filing requirements of a foreign corporation engaged in a trade or business within the United States? (2) If a foreign corporation is engaged in a trade or business within the United States, what is the basis for and the rationale behind disallowing a foreign corporation's deductions and credits for failure to timely file a tax return? (3) If a foreign corporation is engaged in a trade or business within the United States and fails to file a tax return within the time prescribed by Treasury Regulation §1.882-4(a)(3)(i), under what cInternal Revenue Codeumstances will a waiver of the filing deadline be granted and, thus, deductions and credits allowed?
200028029(PDF, 21K)	7/14/2000
Issue: Whether settlement payments made by A to B, stemming from litigation regarding the underpayment of rents and royalties on sales of gas and oil, permit A to use the special computation of tax set forth in Internal Revenue Code § 1341.
200028028(PDF, 10K)	7/14/2000
April 19, 2000 in which you resubmitted the search warrant request in the above referenced case. By memorandum dated, our office declined to authorize the referral of the search warrant to the Tax Division, Department of Justice, citing a lack of probable cause to believe the items sought to be seized were located on the premises to be searched or were likely to contain evidence of the crimes alleged to have been committed.
200028027(PDF, 16K)	7/14/2000
February 8, 2000 requesting that we rule on certain federal income tax consequences of a proposed transaction. The information submitted in that request and in subsequent correspondence is substantially as set forth below.
200028026(PDF, 16K)	7/14/2000
November 4, 1999, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(f) of the Internal Revenue Code.
200028025(PDF, 10K)	7/14/2000
October 15, 1999 requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200028024(PDF, 21K)	7/14/2000
December 13, 1999, submitted on your behalf, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as common parent of the consolidated group of which Sub X is a member) is requesting an extension to file an election under § 338(g) of the Internal Revenue Code with respect to the acquisition of Target and Target's Subs (hereinafter such election is referred to as "the Election").
200028023(PDF, 10K)	7/14/2000
October 15, 1999 requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200028022(PDF, 33K)	7/14/2000
Issues: Whether sufficient facts have been provided to our office to determine whether costs associated with preparing and using steam and CO2 as tertiary injectants are deductible under any provision of the Code, other than § 193, for purposes of § 43(c)(1)(C).
200028021(PDF, 25K)	7/14/2000
February 4, 2000, and prior correspondence, in which your authorized representative requested rulings concerning the manner and timeliness of the qualified terminable interest property (QTIP) election and the "reverse" QTIP elections under §§ 2056(b)(7)(B) and 2652(a)(3) of the Internal Revenue Code, respectively, and the application of the generation-skipping transfer tax allocation rules under § 2632(c)(1).
200028020(PDF, 22K)	7/14/2000
April 10, 2000, and prior correspondence, in which you requested a ruling that the disclaimers executed and delivered by Spouse, Child 1, Child 2, Grandchildren, and Nieces constituted qualified disclaimers under § 2518(b) of the Internal Revenue Code.
200028019(PDF, 34K)	7/14/2000
Issue: Whether the taxpayers realized cancellation of indebtedness income in Tax Year 1.
200028018(PDF, 26K)	7/14/2000
November 18, 1999 (and to the supplemental letters) submitted to the Internal Revenue Service on behalf of Parent by its representative.
200028017(PDF, 8K)	7/14/2000
October 18, 1999, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200028016(PDF, 6K)	7/14/2000
February 16, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200028015(PDF, 6K)	7/14/2000
October 18, 1999, together with subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200028014(PDF, 39K)	7/14/2000
June 8, 1999, and subsequent correspondence, requesting certain rulings on behalf of Trust. Specifically, you requested rulings that certain services performed by Companies B and C will not cause Trust's allocable share of otherwise qualifying income to be excluded from "rents from real property" under § 856(d)(2)(C) of the Internal Revenue Code.
200028013(PDF, 23K)	7/14/2000
September 2, 1999, requesting rulings as to the federal income tax consequences of a proposed transaction. Additional information was received in letters dated February 18, and April 7, 2000.
200028012(PDF, 20K)	7/14/2000
June 7, 1999, submitted by your authorized representative, requesting: (1) an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make a "reverse" qualified terminable interest property election under § 2652(a)(3) of the Internal Revenue Code, and (2) a ruling that the automatic allocation rules of § 2632(c) be deemed to cause the unused portion of the Decedent's generating-skipping tax (GSTT) exemption to be allocated to an exempt martial trust so that such trust has an inclusion ratio of zero.
200028011(PDF, 10K)	7/14/2000
August 20, 1999, requesting rulings as to certain federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated October 25, 1999, March 3, April 5, and April 10, 2000.
200028010(PDF, 8K)	7/14/2000
In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayers, requesting permission to change their accounting period, for federal income tax purposes, from a taxable year ending ________, to a taxable year ending ________, effective _______.
200028009(PDF, 15K)	7/14/2000
April 28, 1999, and letters submitted subsequently on April 29, 1999, October 22, 1999, November 18, 1999, February 2, 2000 and March 9, 2000 on behalf of the above-referenced taxpayer for a private letter ruling consenting to a change of its election under § 936(h)(5)(F) of the Internal Revenue Code of 1986, as amended (hereinafer "Internal Revenue Code"), from the cost sharing method under I.R.C. § 936(h)(5)(C)(i) to the profit split method under I.R.C. § 936(h)(5)(C)(ii).
200028008(PDF, 25K)	7/14/2000
October 9, 1999, submitted by the trustees of Trust requesting a ruling that addresses the estate and gift tax consequences of the proposed change in trustees of Trust. Specifically, the trustees seek a ruling that the proposed resignation of Bank as trustee followed by the proposed appointment of B as trustee and the resulting transfer of the discretionary powers from Bank to B to distribute or refrain from distributing the principal of Trust.
200028007(PDF, 6K)	7/14/2000
July 8, 1999, and subsequent correspondence, requesting rulings on behalf of the Plan concerning the federal income tax treatment of home health care benefits paid under the Plan.
200028006(PDF, 32K)	7/14/2000
January 5, 2000. Field Service Advice is not binding on Examination or Appeals and is not a final case determination.
200028005(PDF, 19K)	7/14/2000
October 6, 1999, in which rulings are requested with regard to a completed transaction involving the above taxpayers. Additional information was submitted in letters dated November 24, 1999 and March 21, 2000.
200028004(PDF, 73K)	7/14/2000
Issues: (1) What is the initial basis in the FSub1 preferred and common stock? (2) How are the October 5, Year 7 contributions, which consisted of contributions by DSub1 to FSub1 of cash and intercompany notes and financing fees in an amount totaling a, reflected in the basis of the common and preferred stock of FSub1?
200028003(PDF, 31K)	7/14/2000
Issues: (1) What is the effective date of the final withholding regulations? (2) Should United Kingdom ("U.K.") intermediaries continue to impose supplemental withholding on payments to account holders in non-treaty countries after the effective date of the final withholding regulations?
200028002(PDF, 38K)	7/14/2000
Issue: Would a determination by the Service not to abate interest on X's income tax liabilities for the years Year 1, Year 2, and Year 3, pursuant to § 6404(e), be an abuse of discretion?
200028001(PDF, 35K)	7/14/2000
Issue: Whether a transferee takes a substituted basis in assets acquired pursuant to a "G" reorganization, and whether the taxpayer in the instant case had basis in the "supervisory goodwill" at issue.
200027064(PDF, 84K)	9/27/2001
This is in response to a ruling request dated November 19, 1999, as supplemented by additional correspondence dated March 19, 2000, and March 28, 2000, from your authorized representative concerning an individual retirement arrangement (IRA) described under § 408(a) of the Internal Revenue Code .
200027063(PDF, 113K)	9/27/2001
This letter constitutes notice that with respect-to the above-named defined benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ending December 31, 1999.
200027062(PDF, 172K)	9/27/2001
This is in reply to your authorized representative's letter dated February 10, 2000 requesting a ruling on the federal tax consequences of certain transactions involving an individual retirement arrangement (IRA). It is & proposed that distributions from IRA Z to Taxpayer A be considered as being distributed as periodic payments as described in § 72(t)(Z)(A)(iv) of the Internal Revenue Code.
200027061(PDF, 208K)	9/27/2001
This is in response to the letter in which you, through your authorized representative, request several letter rulings under § 408(d)(3) of the Internal Revenue Code. The following facts and representations support your ruling request.
200027060(PDF, 187K)	9/27/2001
This is in response to a ruling request dated November 11, 1999, from your authorized representative concerning an individual retirement arrangement (IRA) described under § 408(a) of the Internal Revenue Code .
200027059(PDF, 214K)	9/27/2001
This is in response to your ruling request dated July 1, 1999, submitted by your authorized representative concerning distributions from Plan X, in accordance with § 401(k) of the Internal Revenue Code. A letter dated July (9) 1999, supplemented the request.
200027058(PDF, 345K)	9/27/2001
This is in response to your letter dated May 19, 1999, as supplemented by correspondence dated October 28, 1999, and November 22, 1999, in which your authorized representative requested private letter rulings on your behalf regarding the Federal income tax consequences of a certain transfer from a profit-sharing plan to a money purchase pension.
200027057(PDF, 522K)	9/27/2001
This is in response to the ruling requests submitted to this office on January 13, 2000, on behalf of the three entities described below. The ruling requests concern the effect of a merger, involving two of the entities, upon the tax exempt status of all three entities as well as any unrelated business taxable income which may result there from.
200027056(PDF, 317K)	9/27/2001
This letter is in reply to the letter from your authorized representatives dated October 12, 1999, as amended by letter dated January (6) 2000, in which M and N requested rulings with respect to the tax consequences of a proposed transaction as described below.
200027055(PDF, 599K)	9/27/2001
This is in response to your ruling request that certain proposed transactions will not have adverse consequences under § 501(c)(3), 4941, 4942, or 4945 of the Internal Revenue Code.
200027054(PDF, 318K)	9/27/2001
This is in reply to your rulings request of August 12, 1998, as modified by your letter of October 22, 1999, requesting rulings as to P's proposed transfer of three-fourths of its assets to R, S, and T pursuant to § 507(b)(2) of the Internal Revenue Code.
200027053(PDF, 28K)	7/7/2000
Issue: Whether service centers should print a duplicate of the original notice of deficiency at the time the original notice is printed off the ASFR system?
200027052(PDF, 41K)	7/7/2000
Issue: Should a joint liability be abated when one spouse is relieved of the liability under § 6015, and the other spouse has been discharged in bankruptcy, is deceased and has no estate, or has entered into an offer in compromise?
200027051(PDF, 27K)	7/7/2000
Issues: (1) When does the period for filing a claim for credit or refund under Internal Revenue Code § 6511 and for making an assessment under I.R.C. § 6501 begin to run for an individual income tax return with a Revenue Service Representative? (2) When does the 45 day period of I.R.C. § 6611(e) in which the Service may make a refund of any overpayment without paying interest begin to run for an individual income tax return filed with a Revenue Service Representative?
200027050(PDF, 39K)	7/7/2000
Issue: (1) What kind of a claim should the Internal Revenue Service file in a Chapter 13 bankruptcy case when the tax liabilities have been compromised in a pre-petition offer in compromise if the offer has not yet been fully paid? (2) Is the debtor prohibited from assuming without the Service's consent an accepted offer in compromise that has not been fully paid at the time the Chapter 13 petition was filed because the future compliance provision of the accepted offer makes the contract unassignable under applicable law?
200027049(PDF, 44K)	7/7/2000
Issues: (1) Whether sovereign immunity is a viable defense to the enforcement of income deduction orders that are entered pursuant to § 1325(c) of the Bankruptcy Code against the Service with respect to debtors' future income tax refunds. (2) Whether chapter 13 debtors' future income tax refunds fall within the meaning of "income" in § 1325(c). (3) Whether the Assignment of Claims Act applies to bar the enforcement of an order directing the Service to pay debtors' future income tax refunds to the chapter 13 trustee.
200027047(PDF, 30K)	7/7/2000
April 26, 2000, regarding the tax treatment of employer-reimbursed transportation expenses. This memorandum may be shared with field offices. Chief Counsel Advice is not binding on Examination or Appeals and is not a final case determination.
200027046(PDF, 27K)	7/7/2000
Issue: Whether the Internal Revenue Service has the authority to require security in connection with granting an extension of time to pay estate tax, pursuant to § 6166 of the Internal Revenue Code.
200027045(PDF, 60K)	7/7/2000
Issues: (1) Whether sending a "Last Chance Letter" for a collection summons directly to a represented taxpayer/summoned party violates the prohibition on direct contact in Internal Revenue Code § 6304(a)(2). (2) Whether sending a "Last Chance Letter" with respect to any summons (collection, examination or criminal) to a represented summoned party is an ethical violation of the Model Rules of Professional Conduct Rule 4.2 and various state bar rules of ethics. (3) Whether sending a "Last Chance Letter" to a non-taxpayer summoned party with respect to a non-criminal summons would be a third party contact under I.R.C. § 7602(c). (4) Whether a TDI summons, seeking information to complete a return, issued by a revenue officer would be considered in "connection with the collection of any unpaid tax" for purposes of I.R.C. § 6304(a).
200027044(PDF, 23K)	7/7/2000
August 10, 1999, requesting a ruling on behalf of Employer and Retirement System concerning the federal income tax consequences of certain contributions to Retirement System proposed to be made on behalf of employees of Employer measured by the value of accumulated unused sick pay.
200027043(PDF, 7K)	7/7/2000
February 16, 2000, and subsequent correspondence submitted by X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200027042(PDF, 28K)	7/7/2000
September 13, 1999 requesting, on behalf of the above referenced taxpayers, an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200027041(PDF, 10K)	7/7/2000
December 23, 1999, requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's surrender of his U.S. Alien Registration Card (Green Card) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200027040(PDF, 10K)	7/7/2000
October 27, 1999, as amended by the letter dated March 22, 2000, requesting a ruling under the United States - United Mexican States Income Tax Treaty, signed on September 18, 1992 (the "Treaty"), and § 1441 of the Internal Revenue Code with respect to payments from Annuity Contract to owners and/or beneficiaries who are residents of Mexico under the Treaty and who are not citizens of the United States.
200027039(PDF, 8K)	7/7/2000
January 26, 2000, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation election will be effective D.
200027038(PDF, 6K)	7/7/2000
March 20, 2000, and subsequent correspondence submitted by you as X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200027037(PDF, 13K)	7/7/2000
December 14, 1999, submitted on behalf of Company, requesting rulings under §§ 1362(d)(3) and 1375(a) of the Internal Revenue Code. Company represents the following facts.
200027036(PDF, 38K)	7/7/2000
Issues: (1) What cInternal Revenue Codeumstances warrant the revocation of the conformity election in Treasury Regulation § 1.166-2(d)(3)? (2) In what cInternal Revenue Codeumstances are charge-offs substantially in excess of those warranted by reasonable business judgment for purposes of Treas. Reg. § 1.166- 2(d)(3)(iv)(D)? (3) Should an agent examine the underlying loans to determine a pattern of abuse or must the agent first compare book and tax bad debt deductions to see if there are obvious inconsistencies?
200027035(PDF, 9K)	7/7/2000
September 20, 1999, forwarding Taxpayer's request for an extension of time under Treasury Regulation § 301.9100-3 to file the agreement and certifications described in § 1.1503-2(g)(2) for the taxable years ended on Dates A and B.
200027034(PDF, 20K)	7/7/2000
October 25, 1999, requesting a ruling on behalf of Corporation. Corporation requests a ruling that its cold storage warehouses and central refrigeration systems (described below) constitute real property for purposes of § 856(c) of the Internal Revenue Code.
200027033(PDF, 7K)	7/7/2000
January 24, 2000, submitted by your authorized representative on behalf of Corporation, requesting a ruling under § 1362(b)(5) of the Code that Corporation's S corporation election be effective as of Date.
200027032(PDF, 13K)	7/7/2000
December 23, 1999, and subsequent correspondence, submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(f) of the Internal Revenue Code.
200027031(PDF, 7K)	7/7/2000
February 15, 2000, requesting a ruling under § 1362(b)(5) of the Code that Corporation's S corporation election be effective as of Date.
200027030(PDF, 28K)	7/7/2000
December 14, 1999, and to your supplemental submissions, requesting a ruling that the noncompliance of certain of Taxpayer's policies with the requirements of §§ 101 and 7702 be waived pursuant to §§ 101(f)(3)(H) and 7702(f)(8). This ruling applies to the contracts listed in Exhibit A.
200027029(PDF, 22K)	7/7/2000
June 28, 1999, submitted on behalf of your client, Taxpayer, requesting a ruling that a proposed special assessment to property owners of record on Date 3 qualifies as a contribution to capital under § 118(a) of the Internal Revenue Code.
200027028(PDF, 23K)	7/7/2000
February 8, 2000 requesting a private letter ruling with respect to the application of § 1.1031(k)-1(g)(6)(iii) of the Income Tax Regulations.
200027027(PDF, 17K)	7/7/2000
June 7, 1999 letter, on behalf of the above taxpayers, requesting an extension of time, under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations, to file an election.
200027026(PDF, 51K)	7/7/2000
Issues: (1) Whether tax overpayments for the pre-acquisition years of a consolidated group (GROUP A) may be credited against outstanding tax liabilities for post-acquisition years of the consolidated group (GROUP B) into which the corporate members of the GROUP A were merged, if GROUP A's corporate parent and some GROUP A subsidiaries were liquidated or otherwise ceased to exist after the merger. A. Who is liable for the payment of GROUP B's liabilities for the post-acquisition years? B. Who is entitled to claim and receive a refund of the overpayment of GROUP A's overpayment for the pre-acquisition years? (2) Whether, for purposes of computing interest on equivalent overpayments and underpayments of tax under § 6621(d), the above-referenced overpayments and underpayments are "of the same taxpayer."
200027025(PDF, 13K)	7/7/2000
August 10, 1999, and subsequent correspondence, requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to sever a marital trust (Trust B) into a GST exempt trust and a GST nonexempt trust, and to make a reverse qualified terminable interest property (QTIP) election under § 2652(a)(3) of the Internal Revenue Code, with respect to the exempt GST trust.
200027024(PDF, 6K)	7/7/2000
In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named partnership, requesting permission to adopt an tax year, effective,. The partnership has requested that the Form 1128 be considered timely filed under the authority contained in §301.9100-3 of the Procedure and Administration Regulations.
200027023(PDF, 7K)	7/7/2000
December 14, 1999, together with subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200027022(PDF, 6K)	7/7/2000
In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayers, requesting permission to change their accounting period, for federal income tax purposes, from a taxable year ending ________, to a taxable year ending _______, effective. The taxpayers have requested that the Form 1128 be considered timely filed under the authority contained in § 301.9100-3 of the Procedure and Administration Regulations.
200027021(PDF, 22K)	7/7/2000
September 8, 1999, requesting rulings under § 882 of the Internal Revenue Code of 1986 ("the Code") and the interest article of the income tax treaty between the United States and Country A.
200027020(PDF, 7K)	7/7/2000
December 9, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200027019(PDF, 43K)	7/7/2000
August 13, 1999, and subsequent correspondence, requesting a ruling that City X Tribe will be treated as a political subdivision of a state under § 7871 of the Code for certain federal tax purposes.
200027018(PDF, 33K)	7/7/2000
Requesting rulings under 884 of the Internal Revenue Code of 1986 (the "Code") and the Treasury regulations thereunder (the "Regulations"). Additional information was submitted in letters dated Date b, Date c, and Date d.
200027017(PDF, 12K)	7/7/2000
December 16, 1999, submitted on behalf of the Taxpayer, requesting a private letter ruling on the highest rate of tax specified in § 11 applicable to Taxpayer's nonqualified withdrawal from its capital construction fund under § 7518(g)(6)(A)(ii) of the Internal Revenue Code.
200027016(PDF, 14K)	7/7/2000
September 10, 1999, requesting a ruling concerning the gift tax treatment of the payment of a portion of a federal estate tax liability by two beneficiaries of the decedent's estate.
200027015(PDF, 11K)	7/7/2000
February 17, 2000, and prior correspondence, in which you requested rulings concerning the estate tax consequences of a reformation to a trust.
200027014(PDF, 25K)	7/7/2000
Requesting a ruling concerning the estate and income tax consequences under §§ 2055 and 664 of the Internal Revenue Code related to the proposed reformation of Decedent's Will and the deductibility of the present value of the charitable remainder interests provided for under the reformed Annuity trusts.
200027013(PDF, 10K)	7/7/2000
October 6, 1999, in which a ruling is requested with regard to a transaction involving the above taxpayers. Additional information was submitted in letters dated March 23 and 29, 2000.
200027012(PDF, 15K)	7/7/2000
December 9, 1999, submitted by your authorized representative requesting rulings under § 162(m) of the Internal Revenue Code. Specifically, the rulings requested are that certain nonqualified stock options are "performance-based compensation" under § 162(m)(4)(C) and that the date of the grant of these options for purposes of § 162(m) is the actual date of grant even though the grant is subject to subsequent shareholder approval.
200027011(PDF, 7K)	7/7/2000
In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer, requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending, to a taxable year ending _______, effective ________.
200027010(PDF, 11K)	7/7/2000
December 3, 1998, and subsequent correspondence submitted on behalf of D requesting an extension of time pursuant to §301.9100-3(a) of the Procedure and Administration Regulations to file an election to be disregarded as an entity separate from its owner for federal tax purposes under § 301.7701-3(c).
200027009(PDF, 26K)	7/7/2000
August 23, 1999, requesting a ruling concerning the allocation of Generation-Skipping Transfer Tax (GSTT) exemption under § 2632 of the Internal Revenue Code.
200027008(PDF, 52K)	7/7/2000
Whether premium income received by the Taxpayer's wholly-owned insurance subsidiary from an unrelated insurance company pursuant to a reinsurance agreement should be allocated to the Taxpayer for one or more of the following reasons: (a) the subsidiary is a sham corporation; (b) the reinsurance agreement does not constitute valid reinsurance; and/or (c) the reinsurance transaction otherwise lacks economic substance?
200027007(PDF, 10K)	7/7/2000
April 5, 1999, requesting the Service's determination that the enhanced oil recovery projects in the A and B fields qualify for the credit under § 43 of the Internal Revenue Code.
200027006(PDF, 31K)	7/7/2000
November 30, 1999, the request concerned the use of the math error procedures to disallow exemptions or credits based on taxpayer identification numbers issued to persons who, according to data provided to the Service by the Social Security Administration, are dead.
200027005(PDF, 48K)	7/7/2000
What are the filing requirements of a foreign corporation engaged in a trade or business within the United States? If a foreign corporation is engaged in a trade or business within the United States, what is the basis for and the rationale behind disallowing a foreign corporation's deductions and credits for failure to timely file a tax return?
200027004(PDF, 26K)	7/7/2000
December 22, 1999. Field Service Advice is not binding on Examination or Appeals and is not a final case determination.
200027003(PDF, 15K)	7/7/2000
October 27, 1999, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested by Purchaser to file an election under § 338(g) of the Internal Revenue Code and § 1.338-1(d) of the Income Tax Regulations, with respect to Purchaser's acquisition of the stock of Target on Date A (sometimes hereinafter referred to as the "Election").
200027002(PDF, 18K)	7/7/2000
February 15, 1999, requesting rulings on behalf of L concerning the application of §§ 2601 and 2651 of the Internal Revenue Code.
200027001(PDF, 25K)	7/7/2000
November 18, 1999, and prior correspondence submitted on behalf of Spouse in which rulings are requested concerning the application of §§ 61, 1001, 2511, 2519, 2601, and 2652(a)(3) of the Internal Revenue Code.
200026031(PDF, 104K)	9/27/2001
This is in response to your ruling request of February 10, 2000, requesting advance approval of your scholarship program (Program) pursuant to § 4945(g) of the Internal Revenue Code.
200026030(PDF, 261K)	9/27/2001
This is in response to a letter dated December 27, 1999, in which your authorized representative requested a ruling on your behalf that coverage of employees of Corporation P, an unrelated trade or business, will not adversely affect the status of Plan x as a church plan within the meaning of § 414(e) of the Internal Revenue Code.
200026029(PDF, 190K)	9/27/2001
This is in reply to your request that a set-aside of funds be recognized as satisfying the suitability test of § 4942(g)(2)(B)(l) of the Federal Income Tax Code and therefore a qualifying distribution for the purposes of § 4942(g)(l) of the Code.
200026028(PDF, 256K)	9/27/2001
We have considered your ruling request with regard to the federal income tax consequences of the proposed grants to X to establish a scholarship and fellowship program. The purpose of the scholarship program is designed to expand access to higher education and increase the number of outstanding low income African-American, American Indian/Alaska Native, Asian Pacific American and Hispanic students enrolling in and completing undergraduate and graduate degree programs.
200026027(PDF, 94K)	6/30/2000
The Eleventh CInternal Revenue Codeuit, in an en banc rehearing in Griffith v. United States, 206 F.3d 1389 (11 th Cir. 2000), partially overturned its earlier decision of In re Haas, 48 F.3d 1153 (11 th Cir. 1994), now holding that B.C. § 523(a)(1)(C) renders nondischargeable tax debts where the debtor engaged in affirmative acts constituting a willful attempt to evade or defeat payment of taxes.
200026026(PDF, 94K)	6/30/2000
Bankruptcy does not alter the burden of proof imposed by substantive law. In Raleigh v. Illinois Department of Revenue, 2000 U.S. LEXIS 3623 (S.Ct. May 30, 2000) the Supreme Court ruled that the trustee retained the burden of proof in bankruptcy where underlying state law put that burden on the taxpayer outside of bankruptcy.
200026025(PDF, 24K)	6/30/2000
May 10, 2000, regarding the tax treatment of employer-reimbursed transportation expenses, and it provides additional guidance regarding "temporary" and "regular" work locations for purposes of Rev. Rul. 99-7, 1999-5 I.R.B. 4.
200026024(PDF, 24K)	6/30/2000
Whether an erroneous refund of the Trust Fund Recovery Penalty (TFRP) caused by the Service's error in cross-referencing a payment made by another responsible person can be recovered through administrative means.
200026023(PDF, 28K)	7/1/2000
Section 7602(c) applies to contacts made by a Service employee at the request of the Government. After careful consideration of both the language and history of the statute, we conclude that § 7602(c) does not apply to such contacts because they are not sufficiently causally related to the determination of an internal revenue tax to fall within the statute's ambit.
200026022(PDF, 125K)	6/30/2000
Supreme Court Cases and Related Cases: Terry Stop not justified when based solely on anonymous tip that a person is carrying a gun.
200026021(PDF, 10K)	6/30/2000
November 1, 1999, requesting that Taxpayer be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to complete its compliance with the requirements of Rev. Proc. 98-60, 1998-2
200026020(PDF, 24K)	6/30/2000
In response to the request for a ruling that interest on the Bonds will be excluded from the gross income of holders of the Bonds under § 103(a) of the Internal Revenue Code. Request is submitted as a reviewable ruling under § 4 of Rev. Proc. 96-16, 1996-1 C.B. 630.
200026019(PDF, 70K)	6/30/2000
December 17, 1999 and subsequent correspondence submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200026018(PDF, 71K)	6/30/2000
February 16, 2000, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200026017(PDF, 11K)	6/30/2000
December 2, 1999, together with subsequent correspondence, written on behalf of Company, requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code.
200026016(PDF, 49K)	6/30/2000
Whether premium income received by the Taxpayer's wholly-owned insurance subsidiary from an unrelated insurance company pursuant to a reinsurance agreement should be allocated to the Taxpayer for one or more of the following
200026015(PDF, 23K)	6/30/2000
September 2, 1999, and subsequent correspondence, asking the Internal Revenue Service to rule on the transaction described below.
200026014(PDF, 11K)	6/30/2000
January 14, 2000, together with subsequent correspondence, that P be given an extension of time in which to elect to treat its PLR-102422-00 subsidiaries as qualified subchapter S subsidiaries (QSUBs) under § 1361(b)(3) of the Internal Revenue Code.
200026013(PDF, 21K)	6/30/2000
Ruling Request submitted on behalf of Authority, concerning the status of Authority for purposes of § 141 of the Internal Revenue Code of 1986. On Date 1 we issued a ruling that the Authority is a wholly owned instrumentality of the Members (as defined below) for purposes of §§ 141, 3121(b)(7) and 3306(c)(7). You have requested a ruling that, for purposes of § 141, Authority remains an "instrumentality" of its governmental members.
200026012(PDF, 17K)	6/30/2000
March 18, 1999, as supplemented, submitted on behalf of Corporation requesting rulings under §§ 1361 and 2701 of the Internal Revenue Code.
200026011(PDF, 18K)	6/30/2000
March 18, 1999, as supplemented, submitted on behalf of Corporation requesting rulings under §§ 1361 and 2701 of the Internal Revenue Code.
200026010(PDF, 10K)	6/30/2000
September 29, 1999, submitted on behalf of Estate. You have requested a ruling that the testamentary gift of the residue of Decedent's estate to Trust qualifies for the federal estate tax charitable deduction under § 2055(a) of the Internal Revenue Code.
200026009(PDF, 62K)	6/30/2000
Is a partnership with corporate partners treated as an entity or an aggregate for purposes of determining the fraction a FSC wholly-owned by the partnership should use in calculating the exempt portion (15/23 or 16/23) of its foreign trade income under the FSC administrative pricing rules of § 925?
200026008(PDF, 67K)	6/30/2000
September 14, 1999 letter and subsequent correspondence that X's authorized representative submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200026007(PDF, 9K)	6/30/2000
June 22, 1999, for an extension of time under § 301.9100-1 of the Procedure and Administrative Regulations to make a qualified terminable interest property (QTIP) election under § 2056(b)(7) of the Internal Revenue Code.
200026006(PDF, 49K)	6/30/2000
Whether Taxpayer filed a timely informal claim for refund related to its federal income tax liability for the taxable year ended Day 4 of Year (3) If Taxpayer filed a timely informal refund claim, whether the variance doctrine precludes a refund claim for items unrelated to the rollover adjustments raised in the TL-N-5062-99_WLI2.
200026005(PDF, 45K)	6/30/2000
Whether US Sub1 is liable for an Internal Revenue Code § 6038A(d) monetary penalty for its failure to report on the Form 5472 attached to its Taxable Year 2 Federal income tax return a guarantee fee payment made in Taxable Year 1, which payment served as the basis for an amortization deduction claimed by USSub1 on its Taxable Year 2 return.
200026004(PDF, 17K)	6/30/2000
February 15, 1999, requesting a ruling on behalf of L, as trustee of a marital trust, concerning the application of § 2651(e) of the Internal Revenue Code.
200026003(PDF, 19K)	6/30/2000
November 18, 1999, and prior correspondence submitted on behalf of L in which rulings are requested concerning §§ 2056, 2601, and 2652(a)(3) of the Internal Revenue Code.
200026002(PDF, 18K)	6/30/2000
February 15, 1999, requesting rulings on behalf of N concerning the application of §§ 2601 and 2651 of the Internal Revenue Code.
200026001(PDF, 18K)	6/30/2000
February 15, 1999, requesting rulings on behalf of K, as trustee, concerning the application of §§ 2601 and 2651 of the Internal Revenue Code.
200025064(PDF, 178K)	9/27/2001
This is in response to a ruling request dated December 10 1998. supplemented by correspondence dated July 3 1999. in which you requested rulings through your authorized representative under § 401(k) of the Internal Revenue Code. The following facts and representations were submitted in connection with your request.
200025063(PDF, 224K)	9/7/2001
This is in response to a ruling request dated November (11) 1999. from your authorized representative concerning an arrangement described under § 403(b) of the internal Revenue Code.
200025062(PDF, 406K)	9/7/2001
This is in response to your request for a private letter ruling dated March 16. 1999, as amended by letters dated July 20, 1999, January 26.2000, and March 25.2000, submitted on your behalf by your authorized representative.
200025061(PDF, 230K)	9/7/2001
Request for rulings under § 414(e) of Internal Revenue Code.
200025060(PDF, 453K)	9/7/2001
Ruling request concerning the Federal income tax treatment.
200025059(PDF, 185K)	9/7/2001
This is in response to a letter from your authorized representative regarding the tax consequences associated with the transactions described below.
200025058(PDF, 283K)	9/7/2001
Issues: (1) Whether the proposed transaction will adversely affect the exempt status of A or B under § 501 of the in the Internal Revenue Code. (2) The merger of B into A will not result in a reversion under § 4976[b1)(C) of the Code.
200025057(PDF, 319K)	9/7/2001
This is in response to a letter from your authorized representative requesting a series of rulings on your behalf regarding the tax consequences associated with the transactions described below.
200025056(PDF, 382K)	9/7/2001
This is in response to your ruling request concerning the tax implications under § 501(c)(3). and other applicable sections, of the Internal Revenue Code
200025055(PDF, 36K)	6/23/2000
Whether a Puerto Rican individual who is a citizen or permanent resident of the United States and who is a member of the Armed Forces ("taxpayer") is considered to have a principal place of abode within the United States under § 32(c)(1)(A)(ii)(I) of the Internal Revenue Code of 1986 ("Internal Revenue Code"), and thus possibly be eligible to claim the Earned Income Credit ("EIC")1 in the two situations.
200025054(PDF, 64K)	6/23/2000
In response to the request for technical assistance dated October 27, 1999. We provided a response to some of the questions on February 11, 2000. We are providing an outline of the applicable legal and regulatory provisions as well as responses to your specific questions.
200025053(PDF, 30K)	6/23/2000
In a technical advice memorandum ("TAM") issued by the Assistant Chief Counsel (Corporate), the National Office concluded that for preferred stock to be "structured to avoid the other provisions of [§ 1059] and to enable corporate shareholders to reduce tax through a combination of dividends received deductions and loss on the disposition of the stock" under § 1059(f)(2)(C).
200025052(PDF, 15K)	6/23/2000
We have identified certain broad issues for which additional guidance would be helpful, and we have addressed these issues below. Chief Counsel Advice is not binding on Examination or Appeals and is not a final case determination.
200025051(PDF, 26K)	6/23/2000
Pursuant to the request, we have reviewed the closing agreement that taxpayer's counsel forwarded to our offices on April 8, 2000. As you know, this is the culmination of discussions between our offices and taxpayer's representatives that have extended over a period of more than six months./p>0025050.pdf
200025050(PDF, 29K)	6/23/2000
You have inquired about the employment tax consequences of amounts earned pursuant to a State Statute under which senior citizens can provide services to municipalities in exchange for partial abatement of their property tax liabilities. The Statute allows municipalities to establish a program under which senior citizens can provide services in exchange for a reduction in their property taxes up to the Limit, at an hourly rate not to exceed the State's minimum wage. The workers are termed "volunteers." The amount of the property tax reduction under the Statute is not considered income or wages for purposes of State income tax withholding, unemployment compensation or workmen's compensation. The workers are treated as employees, however, for purposes of municipal tort liability.
200025049(PDF, 34K)	6/23/2000
Whether the Service can, in lieu of taking enforced collection action, accept a promissory note and deed of trust in satisfaction of the taxpayers' tax liabilities, and whether the debts secured by such instruments can be collected notwithstanding the statute of limitations for collection in § 6502 of the Internal Revenue Code.
200025048(PDF, 4K)	6/23/2000
The Internal Revenue Service is reconsidering the applicability of the tax exception in § 48.4061(a)-1(d)(2)(i) of the Manufacturers and Retailers Excise Tax Regulations to trucks on which crane booms are installed.
200025047(PDF, 10K)	6/23/2000
December 13, 1999, requesting a ruling under § 305 of the Internal Revenue Code. Company, a State W corporation, operates as a diversified, closed-end regulated investment company. Company distributes its net investment income monthly and net capital gains annually.
200025046(PDF, 11K)	6/23/2000
December 13, 1999, requesting a ruling under § 305 of the Internal Revenue Code.
200025045(PDF, 7K)	6/23/2000
Letter dated November 15, 1999, and subsequent correspondence submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200025044(PDF, 7K)	6/23/2000
October 1, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200025043(PDF, 17K)	6/23/2000
This responds to your request of November 3, 1999, for a private letter ruling that certain payments in lieu of taxes ("PILOT") are deductible under § 164 of the Internal Revenue Code as real property taxes under the cInternal Revenue Codeumstances described.
200025042(PDF, 8.3K)	6/23/2000
This letter responds to your letter, dated November 18, 1999, and subsequent correspondence, written on behalf of X, requesting a ruling under § 1362(d)(3) of the Internal Revenue Code that the rental income received by X from commercial and residential real properties (including rents received through certain qualified subchapter S subsidiaries (QSubs)) will not constitute passive investment income.
200025041(PDF, 17K)	6/23/2000
This letter responds to your letter, dated January 4, 2000, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation election will be effective as of the taxable year beginning D.
200025040(PDF, 156K)	6/23/2000
This letter is in reply to your letter dated September 15, 1999, requesting rulings as to the federal income tax consequences of a proposed transaction.
200025039(PDF, 6.4K)	6/23/2000
Criminal Tax Bulletin -- Supreme Court Cases
200025038(PDF, 36K)	6/23/2000
This letter is in reply to a request made on behalf of X for consent to an election, pursuant to § 455(c) of the Internal Revenue Code, to apply § 455 to prepaid subscription income.
200025037(PDF, 50K)	6/23/2000
This is in response to your submission dated November 29, 1999, and supplementary submissions requesting on behalf of Taxpayer certain rulings regarding the treatment of sub-accounts of the Separate Account that invest in portfolios ("Portfolios") of Fund A, Fund B, and Fund C (collectively referred to as the "Funds").
200025036(PDF, 14K)	6/23/2000
We respond to your letter dated July 19, 1999, in which you requested rulings as to the federal income tax consequences of a proposed transaction.
200025035(PDF, 11K)	6/23/2000
We respond to your letter dated October 8, 1999, in which you requested rulings under § 302(b)(3) of the Internal Revenue Code on a proposed redemption.
200025034(PDF, 8.0K)	6/23/2000
This responds to a letter dated December 22, 1999, submitted on behalf of X requesting a ruling that as of D1, the C Family members and related C Family trusts were no longer X shareholders within the meaning of § 1362(a)(2), and, therefore, their consent to X's S corporation election, effective D2, is not required.
200025033(PDF, 10K)	6/23/2000
This responds to a letter dated February 16, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200025032(PDF, 6.6K)	6/23/2000
This is in response to your letter dated May 19, 1999, requesting a ruling concerning the application of the unified credit under § § 2010 of the Internal Revenue Code with respect to Decedent's estate.
200025031(PDF, 31K)	6/23/2000
This is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayers, requesting permission to change their accounting period, for federal income tax purposes, from a taxable year ending D1, to a taxable year ending D2, effective D3.
200025030(PDF, 6.7K)	6/23/2000
This is in response to a letter dated November 18, 1999, in which rulings were requested on behalf of Distributing regarding certain federal income tax consequences of a proposed and partially completed transaction.
200025029(PDF, 6.7K)	6/23/2000
This letter responds to a September 14, 1999 letter and subsequent correspondence that X's authorized representative submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200025028(PDF, 6.7K)	6/23/2000
This letter responds to a September 14, 1999 letter and subsequent correspondence that X's authorized representative submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200025027(PDF, 6.7K)	6/23/2000
This letter responds to a September 14, 1999 letter and subsequent correspondence that X's authorized representative submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200025026(PDF, 6.7K)	6/23/2000
This letter responds to a September 14, 1999 letter and subsequent correspondence that X's authorized representative submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200025025(PDF, 6.7K)	6/23/2000
This letter responds to a September 14, 1999 letter and subsequent correspondence that X's authorized representative submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200025024(PDF, 26K)	6/23/2000
This letter responds to a September 14, 1999 letter and subsequent correspondence that X's authorized representative submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200025023(PDF, 8.3K)	6/23/2000
This is in response to your ruling request, dated September 21, 1999, regarding the federal income tax consequences of amounts paid pursuant to the settlement of a class action, including state income tax refunds and interest thereon, administration costs, and attorneys' fees.
200025022(PDF, 15K)	6/23/2000
This responds to a letter dated December 17, 1999, submitted on behalf of Corporation, requesting a ruling under § 1362(g) of the Internal Revenue Code.
200025021(PDF, 75K)	6/23/2000
We received your letter, dated September 17, 1999, requesting a ruling regarding the application of the generation-skipping transfer tax imposed under § 2601 of the Internal Revenue Code to the proposed modification of Trust.
200025020(PDF, 9.2K)	6/23/2000
Whether A traded regulated futures contracts ("RFCs") as defined in Internal Revenue Code §§ 1256(b)(1) and 1256(g)(1).
200025019(PDF, 30K)	6/23/2000
This is in response to a letter dated June 24, 1999, in which a ruling is requested to permit A and B to reelect the foreign earned income exclusion pursuant to § 911 of the Internal Revenue Code.
200025018(PDF, 39K)	6/23/2000
Whether, when a member in his individual capacity enters into an agreement to pay a liability of the limited liability company, the member is at-risk with respect to such amount.
200025017(PDF, 44K)	6/23/2000
Whether a partnership has made a valid election under § 754 in Year 1.
200025016(PDF, 44K)	6/23/2000
This letter responds to your submission of September 15, 1999, together with subsequent correspondence, in which you requested certain rulings under §§ 704, 721, 851, and 7704 of the Internal Revenue Code.
200025015(PDF, 44K)	6/23/2000
This letter responds to your submission of September 15, 1999, together with subsequent correspondence, in which you requested certain rulings under §§ 704, 721, 851, and 7704 of the Internal Revenue Code.
200025014(PDF, 44K)	6/23/2000
This letter responds to your submission of September 15, 1999, together with subsequent correspondence, in which you requested certain rulings under §§ 704, 721, 851, and 7704 of the Internal Revenue Code.
200025013(PDF, 44K)	6/23/2000
This letter responds to your submission of September 15, 1999, together with subsequent correspondence, in which you requested certain rulings under §§ 704, 721, 851, and 7704 of the Internal Revenue Code.
200025012(PDF, 61K)	6/23/2000
This letter responds to your submission of September 15, 1999, together with subsequent correspondence, in which you requested certain rulings under §§ 704, 721, 851, and 7704 of the Internal Revenue Code.
200025011(PDF, 26K)	6/23/2000
Whether the statute of limitations is open for the Tax Court to consider a partner's request for adjustments to the characterization of losses reported by a partnership for other tax years in determining the partner's tax liability for the year to which the losses might be carried forward.
200025010(PDF, 9.5K)	6/23/2000
November 19, 1999, submitted on behalf of the above named taxpayers, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200025009(PDF, 35K)	6/23/2000
January 28, 2000, for a supplemental ruling with respect to a ruling letter dated August 31, 1999 (Control Number PLR-109353-99, LTR 199947020), (the "Prior Letter").
200025008(PDF, 21K)	6/23/2000
Whether Internal Revenue Code § 807(e)(1)(B), which provides a special rule requiring that the net surrender value of pension contracts be reduced by surrender charges, applies to pension reserves taken into account under § 807(c)(4);
200025007(PDF, 19K)	6/23/2000
Is Taxpayer liable for the excise tax imposed by § 4051(a)(1)(E) of the Internal Revenue Code on a tractor when it makes the first retail sale of the vehicle described below?
200025006(PDF, 15K)	6/23/2000
Is Taxpayer liable for the excise tax imposed by § 4051(a)(1)(E) of the Internal Revenue Code on a tractor when it makes the first retail sale of the vehicle described below?
200025005(PDF, 11K)	6/23/2000
August 17, 1999, on behalf of the Employer requesting a ruling on the federal tax consequences of the Plan and Trust.
200025004(PDF, 45K)	6/23/2000
Whether the Facility, used for the purpose of curing cheese, is a manufacturing facility under § 144(a)(12)(C) of the Internal Revenue Code.
200025003(PDF, 36K)	6/23/2000
Whether tax overpayments by a state or by a state school that files separate returns may be credited against outstanding tax liabilities of the state or another state school under § 6402(a).
200025002(PDF, 33K)	6/23/2000
Whether Taxpayer's payment of an amount determined to be due upon an audit of earlier taxable years and representing its employees' portion of additional withholding and FICA taxes on certain meal allowances is deductible as an ordinary and necessary business expense under § 162.
200025001(PDF, 48K)	6/16/2000
January 26, 1999, in which you requested rulings as to the federal income tax consequences of a proposed transaction.

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2000 Chief Counsel'sWritten Determinations

2000 Chief Counsel's
Written Determinations