2000 Chief Counsel's
Written Determinations
200035000 to 200039999
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.
All files below are in the Adobe Acrobat PDF Format.
| 200039038(PDF, 46K) |
9/20/2000 |
| Whether, under the cInternal Revenue Codeumstances described below, a casino patron (customer) realizes discharge of indebtedness income when a casino accepts less than the face amount of the customer's marker (a debt instrument) in full satisfaction of the marker pursuant to a prearranged agreement with the customer. |
| 200039037(PDF, 46K) |
9/20/2000 |
| Whether, under the cInternal Revenue Codeumstances described below, a casino patron (customer) realizes discharge of indebtedness income when a casino accepts less than the face amount of the customer's marker (a debt instrument) in full satisfaction of the marker pursuant to a prearranged agreement with the customer. |
| 200039036(PDF, 407K) |
10/4/2001 |
| This letter is in reply to a request for a letter ruling dated July 7, 1998, as supplemented by submissions of December 3, 1998, November 16, 1999, and June 22, 2000, made on behalf of Employer M, concerning the federal tax treatment of certain contributions made to Plan X and Plan Y under § 414(h) (2) of the Internal Revenue Code. |
| 200039035(PDF, 88K) |
10/4/2001 |
| This letter constitutes notice that a conditional waiver of the minimum funding standard has been granted for the above named pension plan for the plan year ended December 31, 1999. The conditional waiver has been granted in accordance with § 412(d) of the Internal Revenue Code (the "Code") and § 303 of the Employee Retirement Income Security Act of 1974 (ERISA). The amount for which the waiver has been granted is the contribution which would otherwise be required to reduce the balance in the funding standard account of the plan to zero as of the end of the plan year for which the waiver bas been granted. |
| 200039034(PDF, 16K) |
9/21/2000 |
| Whether the hazards of litigation are such that penalties should be abated, under § 6404, under the facts as described below. |
| 200039033(PDF, 14K) |
9/12/2000 |
| This letter responds to your February 18, 2000 request for rulings concerning the federal income tax consequences of a proposed transaction. |
| 200039032(PDF, 11K) |
9/20/2000 |
| The Prior Letter Ruling addresses certain federal income tax consequences of a then proposed restructuring of the Distributing group that has since culminated in (i) the transfer by Distributing of Business D to Controlled for Controlled stock, (ii) an initial public offering of less than a percent of the Controlled stock (the "IPO"), and (iii) distribution of the remaining Controlled stock pro rata to Distributing's shareholders. |
| 200039031(PDF, 13K) |
9/12/2000 |
| This is in response to your letter dated June 29, 2000, and prior correspondence, in which you request several rulings concerning the application of § 2702 of the Internal Revenue Code. |
| 200039030(PDF, 4.3K) |
9/12/2000 |
| On November 14, 1980, the Internal Revenue Service (IRS) issued a letter ruling, LTR 8106055, to Taxpayer concerning the excise tax on the air transportation of persons imposed by § 4261 of the Internal Revenue Code. |
| 200039029(PDF, 25K) |
9/20/2000 |
| In accordance with § 8.07(2)(b) of Rev. Proc. 2000-1, 2000-1 I.R.B., 4, 33, we are notifying you that a February 2, 2000, ruling request that was submitted to this office, requesting rulings under § 280G of the Internal Revenue Code, was withdrawn in anticipation of adverse rulings. |
| 200039028(PDF, 11K) |
9/12/2000 |
| This is in reply to a request for rulings concerning the deduction limitation of § 162(m) of the Internal Revenue Code. |
| 200039027(PDF, 18K) |
9/12/2000 |
| The requested ruling is that Taxpayer's allocable share of payments received by LP1 resulting from the settlement of a lawsuit and other legal claims described below are not includible in Taxpayer's gross income solely for purposes of the gross income tests described in §§ 856(c)(2) and 856(c)(3) of the Internal Revenue Code. |
| 200039026(PDF, 7.3K) |
9/12/2000 |
| This letter responds to a letter dated March 20, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200039025(PDF, 8.1K) |
9/12/2000 |
| This responds to your letter dated June 12, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200039024(PDF, 8.3K) |
9/12/2000 |
| This letter responds to the ruling request dated June 13, 2000, that was submitted by your representative on behalf of X, and which requests relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200039023(PDF, 7.9K) |
9/12/2000 |
| This responds to a letter dated February 25, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200039022(PDF, 22K) |
9/12/2000 |
| We reply to a letter, dated February 22, 2000, from your representatives in which rulings are requested as to the federal income tax consequences of a proposed transaction. |
| 200039021(PDF, 15K) |
9/21/2000 |
| This is in response to a letter dated March 7,2000, for rulings concerning the federal income tax consequences of a proposed transaction. |
| 200039020(PDF, 7.3K) |
9/12/2000 |
| This letter responds to a letter dated May 3, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200039019(PDF, 7.3K) |
9/12/2000 |
| This letter responds to a letter dated March 10, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200039018(PDF, 9.3K) |
9/12/2000 |
| This letter responds to a letter dated May 19, 2000, written on behalf of X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c). |
| 200039017(PDF, 35K) |
9/12/2000 |
| The activities of LLC1 and Corporation C will not cause Trust's share of rents received by OP from OP tenants that are clients of LLC1, to be considered as other than "rents from real property" under § 856(d) of the Internal Revenue Code; |
| 200039016(PDF, 7.6K) |
9/12/2000 |
| This responds to your letter dated June 2, 2000, submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200039015(PDF, 7.4K) |
9/20/2000 |
| This responds to the letter dated May 15, 2000 and previous correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200039014(PDF, 9.8K) |
9/12/2000 |
| This letter responds to a letter dated February 24, 2000, written on behalf of X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c). |
| 200039013(PDF, 8.2K) |
9/12/2000 |
| This responds to your letter dated May 22, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200039012(PDF, 11K) |
9/12/2000 |
| This responds to a letter dated March 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200039011(PDF, 11K) |
9/12/2000 |
| This responds to a letter dated March 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200039010(PDF, 11K) |
9/11/2000 |
| This responds to a letter dated March 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200039009(PDF, 11K) |
9/12/2000 |
| This responds to a letter dated March 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200039008(PDF, 14K) |
9/20/2000 |
| This is in response to your letter dated February 15, 2000, on behalf of the Employer requesting a ruling on the federal tax consequences of the Plan. Employer intends the Plan to be an eligible deferred compensation plan under § 457 of the Internal Revenue Code of 1986. |
| 200039007(PDF, 36K) |
9/11/2000 |
| Whether a net operating loss can be applied to a year discharged in bankruptcy. |
| 200039006(PDF, 14K) |
9/12/2000 |
| Are certain payments that the Taxpayers received for foster care in Year 1 and Year 2 qualified foster care payments under § 131 of the Internal Revenue Code? |
| 200039005(PDF, 19K) |
9/11/2000 |
| Under the facts of this case, does the transaction constitute a deferred exchange and thus qualify for nonrecognition as a like kind exchange? |
| 200039004(PDF, 7.8K) |
9/20/2000 |
| Whether Taxpayer can exclude documentation fees from the tax base when computing the federal luxury excise tax imposed on the sale of passenger vehicles under § 4001(a) of the Internal Revenue Code? |
| 200039003(PDF, 13K) |
9/20/2000 |
| We received the June 23, 1999, request for rulings concerning the estate, gift, and generation-skipping transfer tax consequences of the creation of a trust. |
| 200039002(PDF, 14K) |
9/12/2000 |
| This is in response to your request for a ruling dated September 30, 1999, on behalf of X concerning the income tax consequences of the nonqualified deferred compensation agreement (the "Plan") and a trust agreement (the "Trust") established by X. |
| 200039001(PDF, 22K) |
9/20/2000 |
| We received the March 22, 1999, letter and later submissions requesting rulings concerning the income, gift, and generation-skipping transfer tax consequences of the proposed division of a trust. |
| 200038059(PDF, 8.3K) |
9/25/2000 |
| By memorandum dated July 25, 2000, we originally responded to your questions concerning whether parents were entitled to a dependency exemption for a minor child who was kidnapped by a stranger and was still missing at year end. |
| 200038058(PDF, 439K) |
10/4/2001 |
| This is in response to your request, dated April 5, 2000, and amended on June 28, 2000, for rulings concerning the election to cease status as a qualified scholarship funding corporation (QSFC) for the purposes of § 150(d) of the Internal Revenue Code, and the federal income tax consequences of your transfer of obligations and assets that secure them to a for-profit entity pursuant to § 150(d)(3). |
| 200038057(PDF, 375K) |
10/4/2001 |
| Requesting rulings on your behalf in your capacity as an individual taxpayer and as Chairman & CEO of Employer M regarding the Federal income tax treatment of certain distributions from a defined contribution plan that includes an employee stock ownership plan (ESOP). |
| 200038056(PDF, 222K) |
10/4/2001 |
| This is in reference to your letter of March 1, 2000, requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200038055(PDF, 415K) |
10/4/2001 |
| This is in response to a letter dated May 26, 1999, as supplemented by correspondence dated October 22, and 26, 1999, submitted on your behalf by your authorized representative for a ruling concerning the federal income tax treatment under § 414(h) (2) and 402(c) (4) of the Internal Revenue Code of certain contributions to System C. |
| 200038054(PDF, 182K) |
10/4/2001 |
| This refers to your ruling request under § 501 (c)f91 and 4976 of the internal Revenue Code. |
| 200038053(PDF, 162K) |
10/4/2001 |
| Issues: 1.The proposed grant program: (a) is consistent with continuation of [your] exempt status as an organization described in § 501(c)(3), contributions to which are deductible under § 170 of the Code; (b) employs objective and nondiscriminatory criteria for the determination of individual grant recipients and therefore, qualifies under Code § 4945(g); (c) complies with all other requirements of § 53.4945-l of the regulations. (2) A re-grant by an initial grantee to an individual under the proposed grant program will not violate the terms of [your] expenditure responsibility grant agreement with the Initial Grantee, which is required by § 53.4945-5(b)(3)(iv)(c) of the regulations. |
| 200038052(PDF, 336K) |
10/4/2001 |
| This is in response to a ruling request submitted to this office on your behalf by your authorized representative by letter dated April 29, 1999, as supplemented by a letter dated November 15, 1999. You have requested a ruling under § 402(e)(4)(8) of the Internal Revenue Code . |
| 200038051(PDF, 454K) |
10/4/2001 |
| This is in response to the request for letter ruling, submitted on your behalf by your authorized representative, as supplemented by correspondence, in which you request several letter rulings under § 162, 401(a) (41, 401(a) (16), 402, 404, 415 and 4912 of the Internal Revenue Code. |
| 200038050(PDF, 1.0M) |
10/4/2001 |
| This is in response to the request for letter ruling, submitted on your behalf by your authorized representative, as supplemented by correspondence dated and in which you request a series of rulings under § 72,401,402, 509, 664, and 1223 of the Internal Revenue Code. The following facts and representations support your ruling request. |
| 200038049(PDF, 255K) |
10/4/2001 |
| This is in reply to a letter dated April 28, 2000, from your legal representative in which she requested rulings concerning the income tax consequences of certain transactions arising from a proposed corporate reorganization. |
| 200038048(PDF, 225K) |
10/4/2001 |
| This is in reply to a ruling request dated January 21, 2000, with respect to advance approval of your grant making procedures under § 4945(g) of the Internal Revenue Code. |
| 200038047(PDF, 18K) |
9/22/2000 |
| Issue: 1997, taxpayers in Grand Forks, North Dakota, and Polk County, Minnesota, (affected taxpayers) were affected by a Presidentially declared disaster. Notice 97- 62 granted affected taxpayers 6-month extensions of time to file their 1996 tax returns under § 6081 and pay their 1996 tax liability under § 6161. In addition, Notice 97-62 provided that under § 7508A a specified period of time was disregarded in determining whether affected taxpayers timely performed certain acts, including the filing of refund claims; this period was also disregarded in determining the amount of the refund. See §§ 7508A(a)(2) and 6511(b)(2)(A). Determine the date by which an affected taxpayer must file a refund claim in order obtain a refund of estimated tax and withheld income tax for 1996 that was deemed paid on April 15, 1997. |
| 200038046(PDF, 58K) |
9/22/2000 |
| Issues: (1) What are the requirements of the discovery test for the years in issue? (2) What are the requirements of the process of experimentation test for the years in issue? |
| 200038045(PDF, 36K) |
9/22/2000 |
| Issues: (1) Whether the Service may use evidence that was obtained from an intercepted wire communication (wiretap) relating to an act not enumerated in 18 U.S.C. § 2516 without a derivative use order as required by 18 U.S.C. § 2517(5). (2) Whether the Service is permitted to request a nunc pro tunc derivative use order to be applied retroactively to the evidence obtained from the wiretap. (3) Whether the evidence obtained from a legally authorized intercepted wire communication would be suppressed if the Service fails to obtain a derivative use order. |
| 200038044(PDF, 18K) |
9/22/2000 |
| This responds to Taxpayer’s request for a private letter ruling dated March 13, 1998. Specifically, Taxpayer has requested a ruling that the termination of Taxpayer’s power purchase agreement (“PPA”) pursuant to the Agreement constitutes a “compulsory or involuntary conversion” of its PPA within the meaning of §§ 1033 and 1231 of the Internal Revenue Code. Taxpayer has also requested rulings that the amount of any gain (or loss) required to be recognized by Taxpayer in connection with the conversion of its PPA is a § 1231 gain or § 1231 loss. |
| 200038043(PDF, 28K) |
9/22/2000 |
| As a follow-up to the advice we issued in January 2000 (IRS CCA 200009043; 2000 IRS CCA Lexis 1), you have asked for additional technical advice involving several areas related to corporate officer compensation and classification. We welcome the opportunity to provide additional written guidance and clarification in these areas. For clarity, these issues have been separately numbered and discussed below. |
| 200038042(PDF, 28K) |
9/22/2000 |
| Issue: Whether the Service is required to issue a second refund where the Taxpayer used the Volunteer Income Tax Assistance (VITA) program to electronically file her return and a person with access to the VITA Site subsequently changed the account and routing numbers for her refund deposit so that a third person obtained Taxpayer’s refund. |
| 200038041(PDF, 19K) |
9/22/2000 |
| This letter responds to your request, dated November 29, 1999, that we rule on certain tax consequences of the sale of the Plants from Seller to Buyers. As set forth below, you have requested rulings regarding the tax consequences under § 468A of the Internal Revenue Code to the Seller’s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the Plants. |
| 200038040(PDF, 180K) |
9/26/2000 |
| Bulletin No. 478 - Collection, Bankruptcy and Summonses Bulletin |
| 200038039(PDF, 10K) |
9/22/2000 |
| This letter responds to your request, dated November 29, 1999, that we rule on certain tax consequences of the sale of the Plants from Seller to Buyers. As set forth below, you have requested rulings regarding the tax consequences under § 468A of the Internal Revenue Code to the Seller’s qualified nuclear decommissioning fund as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the Plant. |
| 200038038(PDF, 8K) |
9/22/2000 |
| Issues: (1) Should the Service conduct separate §§ 6707/6708 penalty examinations for each individual shelter promoted, or an aggregate examination of all the tax shelter organizer's shelters, when an organizer failed to register more than one § 6111 shelter? (2) What are the organizer's administrative appeals rights? (3) Is a § 6707 exam part of an income tax exam? If the Service conducts a § 6707 concerning a particular deal, is it prohibited from conducting another |
| 200038037(PDF, 19K) |
9/22/2000 |
| Issue: Under what cInternal Revenue Codeumstances should the Internal Revenue Service issue EINs to prisoners? |
| 200038036(PDF, 7K) |
9/22/2000 |
| We received your letter, dated September 27, 1999, requesting rulings on the proper income, gift and generation-skipping transfer tax treatment of the proposed partition of a trust into separate trusts. This letter responds to your request. |
| 200038035(PDF, 15K) |
9/22/2000 |
| We respond to your February 29, 2000 request for rulings on certain federal income tax consequences of a series of proposed transactions. The information submitted in that request and in later correspondence is summarized below. Distributing’s predecessors received rulings on prior transactions during Year 1, Year 2, and Year 3 (the “Prior Ruling Letters”). |
| 200038034(PDF, 19K) |
9/22/2000 |
| This letter responds to a letter dated November 23, 1999, and subsequent correspondence, submitted on behalf of X by its authorized representative, requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200038033(PDF, 11K) |
9/1/2000 |
| This responds to a letter dated March 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200038032(PDF, 12K) |
9/22/2000 |
| This letter replies to a request for rulings, dated March 20, 2000, on the federal income tax consequences of a proposed transaction concerning § 355 of the Internal Revenue Code. We received additional information in letters dated April 5, April 22, May 15, May 30, and June 16, 2000. |
| 200038031(PDF, 11K) |
9/22/2000 |
| This letter responds to your request dated April 6, 2000 (the "Supplemental Ruling Request"), for a letter ruling supplementing our letter ruling dated January 15, 1998 (PLR-115035-97, the "Prior Letter Ruling"). The Prior Letter Ruling concerned proposed split-off transaction (the “Split-off Transaction”). The Split-off Transaction not, as yet, been completed because an illness affecting one of Distributing’s shareholders prevented the completion of negotiations with Distributing’s lenders for debt restructuring related to the Split-off Transaction. The shareholder has recovered and the parties are prepared to complete the Split-off Transaction. This supplemental letter ruling revokes the Prior Letter Ruling and addresses the federal tax consequences of the currently proposed transaction. Additional information was submitted in letters dated May 9, 2000, and May 12, 2000. The facts submitted are summarized below. |
| 200038030(PDF, 12K) |
9/22/2000 |
| This is in reply to your request for assistance dated May 19, 2000, regarding whether information returns are required under § 6050I of the Internal Revenue Code in connection which rental receipts for taxi medallions by taxicab fleets and taxi management companies. |
| 200038029(PDF, 12K) |
9/22/2000 |
| Issue: When a penalty equal to three times the scholarship funds awarded, plus interest, is imposed for an individual’s failure to complete the required period of service for a scholarship awarded under the Indian Health Scholarship Program, and the penalty is subsequently discharged, is there discharge of indebtedness income under § 61(a)(12) in the amount of the discharged penalty? |
| 200038028(PDF, 7K) |
9/22/2000 |
| Issues: (1) Whether the Service’s use of computer software executable code obtained in the course of an audit is permissible under § 7612(c)(2)(A) of the Internal Revenue Code in the following three situations. a. The Service uses the computer software executable code and the taxpayer's data files to perform "what if" computations, making changes to the taxpayer's data, and the computer software executable code is used to determine the tax consequences of those changes; b. The Service uses the computer software executable code and the taxpayer's data files and adjusts those files to incorporate proposed adjustments to the amount or classification of items of income or expense. The computer software executable code is then used to compute proposed tax adjustments and a revised Form 1118 (foreign tax credit computation) and related schedules; and c. The Service uses the computer software executable code and the taxpayer’s data files to generate input data files and output reports, which are then used by the Service for its examination of the taxpayer’s return using a software program that the Service has developed internally, or which the Service has purchased or licensed from a third party. (2) Would those uses cause the Service to be using the commercial vendor’s computer software executable code without a license or other authorization? (3) Should the Service secure permission from the foreign tax credit commercial vendors to use their computer software executable code as described in the three scenarios? |
| 200038027(PDF, 8K) |
9/22/2000 |
| This in response to your request for a private letter ruling that the Facility will be a qualified residential rental project for purposes of § 142(d). |
| 200038026(PDF, 7K) |
9/22/2000 |
| This is in response to your submission of April 20, 2000, in which you requested a ruling under § 2652 of the Internal Revenue Code and § 301.9100-1 of the Procedure and Administration Regulations. |
| 200038025(PDF, 40K) |
9/22/2000 |
| Issue: Whether Company B’s method of determining the amount of the company’s share and the policyholders’ share for purposes of claiming a dividends received deduction is appropriate under § 812 of the Internal Revenue Code. |
| 200038024(PDF, 12K) |
9/22/2000 |
| This is in reply to a letter dated January 10, 2000, and subsequent correspondence, requesting that Fund 1, Fund 2 and Fund 3 (Funds) each be granted an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make a consent dividend election under § 565 of the Internal Revenue Code. |
| 200038023(PDF, 7K) |
9/22/2000 |
| This in response to your private letter ruling request, on behalf of X, for an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to file an election under § 146(f) of the Internal Revenue Code to carryforward excess private activity bond volume cap from 1999. |
| 200038022(PDF, 9K) |
9/22/2000 |
| This responds to a letter dated March 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200038021(PDF, 19K) |
9/22/2000 |
| This responds to a letter dated March 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200038020(PDF, 9K) |
9/22/2000 |
| This responds to a letter dated March 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200038019(PDF, 9K) |
9/22/2000 |
| This responds to a letter dated March 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200038018(PDF, 8K) |
9/22/2000 |
| This responds to a letter dated April 28, 2000, submitted on behalf of A, requesting an extension of time pursuant to § 301.9100-3(a) of the Procedure and Administration Regulations to file an election to be treated as a corporation for federal tax purposes under § 301.7701-3(c). |
| 200038017(PDF, 8K) |
9/22/2000 |
| We respond to your letter dated May 12, 2000, in which you requested rulings on the federal income tax consequences of a completed transaction and a proposed transaction under § 368(a)(1)(A). Pursuant to § 3.01(23) of Rev. Proc. 2000-3, 2000-1 I.R.B. 103,105, the Internal Revenue Service will not rule as to whether a proposed transaction qualifies under § 368(a)(1)(A). However, the Service has discretion to rule on significant subissues that must be resolved to determine whether a transaction qualifies under § 368(a)(1)(A). The information submitted for our review is summarized as follows. |
| 200038016(PDF, 6K) |
9/22/2000 |
| This responds to a letter submitted on behalf of Partnership requesting that Partnership be given an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200038015(PDF, 7K) |
9/22/2000 |
| This responds to a letter submitted on behalf of Partnership requesting that Partnership be given an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200038014(PDF, 28K) |
9/22/2000 |
| This responds to a letter submitted on behalf of Partnership requesting that Partnership be given an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200038013(PDF, 52K) |
9/22/2000 |
| This responds to a letter dated April 12, 2000, submitted on behalf of A, requesting an extension of time pursuant to §301.9100-3(a) of the Procedure and Administration Regulations to file an election to be treated as a corporation for federal tax purposes under § 301.7701-3(c). |
| 200038012(PDF, 25K) |
9/22/2000 |
| Pursuant to a power of attorney on file in this office, this responds to a ruling request dated June 2, 2000, submitted on behalf of X , which requests relief under §1362(b)(5) of the Internal Revenue Code. |
| 200038011(PDF, 9K) |
9/22/2000 |
| This responds to a letter submitted on behalf of Partnership requesting that Partnership be given an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200038010(PDF, 10K) |
9/22/2000 |
| This responds to a letter submitted on behalf of Partnership requesting that Partnership be given an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200038009(PDF, 32K) |
9/22/2000 |
| This responds to a letter dated March 22, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200038008(PDF, 15K) |
9/22/2000 |
| This responds to your letter dated March 8, 2000, submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200038007(PDF, 32K) |
9/22/2000 |
| This responds to your letter dated March 8, 2000, submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200038006(PDF, 13K) |
9/22/2000 |
| This letter responds to your letter, dated March 2, 2000, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200038005(PDF, 36K) |
9/22/2000 |
| This letter responds to a letter, dated April 13, 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. |
| 200038004(PDF, 32K) |
9/22/2000 |
| Issue: Whether Company A is entitled to deduct contributions to Plan X for the taxable year ending January 31, 1998. |
| 200038003(PDF, 26K) |
9/14/2000 |
| The purpose of this memorandum is to indicate a change in a position previously set forth in a June 16, 2000, memorandum for your office on the "Processing Offers in Compromise During or After Collection Due Process Proceedings" topic. |
| 200038002(PDF, 35K) |
8/31/2000 |
| Whether funds held by a publishing services company in an account for benefit of Taxpayer, and subject to "draws" by Taxpayer, were income to Taxpayer when received by the company and credited to Taxpayer's accounts. |
| 200038001(PDF, 17K) |
9/22/2000 |
| This letter responds to your letter dated April 17, 2000, and subsequent correspondence, written on behalf of X as its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200037053(PDF, 252K) |
10/4/2001 |
| This letter is in response to your letter dated April 13, 2000 and subsequent correspondence requesting a ruling under § 170(b)(l)(A)(vi) and 509(a)(l) of the Internal Revenue Code. |
| 200037052(PDF, 205K) |
10/4/2001 |
| This is in reply to the letter submitted on behalf of M regarding the proposed consolidation of certain retiree life, medical and dental benefits which are currently funded by M through two welfare benefit trusts. |
| 200037051(PDF, 401K) |
10/4/2001 |
| This is in reply to your rulings request of August 13, 1999, on P's proposed transfers of all of its assets to S, T, U, V, and W pursuant to § 507(b)(2) of the Internal Revenue Code. |
| 200037050(PDF, 244K) |
10/4/2001 |
| This letter is in reply to the letter from your authorized representative dated September 8, 1999, as amended by letter dated January 18, 2000, in which M requested rulings with respect to the tax consequences of the formation of a tax exempt entity as a holding company and the formation of a profit making subsidiary as described below. |
| 200037049(PDF, 174K) |
10/4/2001 |
| This is in reply to your ruling request of December 23, 1999. You have requested approval of a proposed set aside of your income under the suitability test of § 4942(g)(2)(B)(i) of the Internal Revenue Code and § 53,4942(a)(b)(2) of the Foundation and Similar Excise Taxes Regulations. |
| 200037048(PDF, 53K) |
8/17/2000 |
| Your request for Technical Assistance raises several questions regarding how the substantial and gross valuation misstatement penalties under § 6662(b)(3) and described in § 6662(e)(1)(B) and 6662(h) (hereinafter the "Penalties," unless otherwise specified) are calculated. |
| 200037047(PDF, 82K) |
9/8/2000 |
| Does the Service 's policy not to process OICs from taxpayers in bankruptcy violate the anti-discrimination provision of the Bankruptcy Code? |
| 200037046(PDF, 108K) |
9/15/2000 |
| The constitutional privilege against self-incrimination protects the target of a grand jury investigation from being compelled to answer questions designed to elicit information about the existence of the sources of potentially incriminating evidence, held the Supreme Court in United States v. Hubbell, 2000 U.S. LEXIS 3768 (S. Ct. June 5, 2000). Further, the Court held, that constitutional privilege applies equally to the testimonial aspect of a response to a subpoena seeking discovery of those sources. |
| 200037045(PDF, 40K) |
8/15/2000 |
| This is in response to your authorized representative's letter dated February 3, 2000, requesting rulings under §§ 351 and 355 of the Internal Revenue Code (the "Code") with respect to a proposed series of transactions. |
| 200037044(PDF, 7.4K) |
8/15/2000 |
| This responds to the letter dated March 3, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200037043(PDF, 20K) |
8/15/2000 |
| This in response to a letter dated April 6, 2000, submitted by your authorized representative, requesting an extension of time to make a joint election pursuant to §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations. |
| 200037042(PDF, 7.6K) |
8/15/2000 |
| This responds to your letter dated May 5, 2000, submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200037041(PDF, 7.3K) |
8/15/2000 |
| This letter responds to a letter dated January 11, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200037040(PDF, 42K) |
9/14/2000 |
| Is the Organization an exempt political organization, within the meaning of § 527 of the Internal Revenue Code? |
| 200037039(PDF, 50K) |
9/7/2000 |
| What discretion does the Service have to issue an expedited refund pending the completion of a tax examination after accepting a surety bond to secure the tax to be refunded, if a potential whipsaw situation precludes the Service from determining an overpayment? |
| 200037038(PDF, 10K) |
8/15/2000 |
| This is in response to a letter from your authorized representative dated January 19, 2000, requesting a ruling on your behalf under § 877(c) of the Internal Revenue Code of 1986 (the "Code") that your loss of permanent 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. |
| 200037037(PDF, 10K) |
9/7/2000 |
| This is in response to a letter from your authorized representative dated January 19, 2000, requesting a ruling on your behalf under § 877(c) of the Internal Revenue Code of 1986 (the "Code") that your loss of permanent 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. |
| 200037036(PDF, 27K) |
8/15/2000 |
| This is in response to a request you submitted on behalf of the Authority for a ruling under § 103 of the Internal Revenue Code of 1954 (the "1954 Code") about the effect that a sale of the Plants will have upon interest paid on bonds that financed all or some portion of the Plants. |
| 200037035(PDF, 16K) |
9/7/2000 |
| Distributing is the common parent of an affiliated group whose includible members join in filing a consolidated federal income tax return. Distributing has outstanding Class A voting common stock (the "Distributing Voting Common"), Class B nonvoting common stock (the "Distributing Nonvoting Common"), and cumulative preferred stock (the "Distributing Preferred"). |
| 200037034(PDF, 42K) |
9/7/2000 |
| Whether service fees should be treated as interest for purposes of Internal Revenue Code § 265(a)(2). Whether periodic and nonperiodic payments made pursuant to notional principal contracts should be treated as interest for purposes of § 265(a)(2). Whether a commitment fee paid to obtain a line of credit should be treated as interest for purposes of § 265(a)(2). |
| 200037033(PDF, 15K) |
8/15/2000 |
| This letter responds to a letter dated February 10, 2000, requesting a ruling as to the federal income tax consequences of a proposed transaction. |
| 200037032(PDF, 8.1K) |
8/15/2000 |
| This responds to the letter dated April 5, 2000, submitted by your representative on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200037031(PDF, 8.3K) |
9/7/2000 |
| This letter responds to the ruling request dated May 25, 2000, that was submitted by your representative and which requests relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200037030(PDF, 6.8K) |
9/8/2000 |
| This responds to your letter dated February 5, 2000, and subsequent correspondence, that you submitted on Partnership's behalf, requesting an extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200037029(PDF, 6.8K) |
9/8/2000 |
| This responds to your letter dated February 5, 2000, and subsequent correspondence, that you submitted on Partnership's behalf, requesting an extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200037028(PDF, 6.8K) |
9/8/2000 |
| This responds to your letter dated February 5, 2000, and subsequent correspondence, that you submitted on Partnership's behalf, requesting an extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200037027(PDF, 47K) |
9/7/2000 |
| Whether for tax year 1997 foreign oil and gas extraction income ("FOGEI") for purposes of the limitation of § 907(a) of the Internal Revenue Code includes income from extraction of oil and gas from wells located within the United States. |
| 200037026(PDF, 6.8K) |
9/8/2000 |
| This responds to your letter dated February 5, 2000, and subsequent correspondence, that you submitted on Partnership's behalf, requesting an extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200037025(PDF, 7.7K) |
8/15/2000 |
| This responds to your representative's letter dated May 17, 2000, submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200037024(PDF, 7.3K) |
8/15/2000 |
| This letter responds to a letter dated March 1, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200037023(PDF, 10K) |
8/15/2000 |
| This letter responds to your letter on behalf of Company, dated May 17, 2000, requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200037022(PDF, 8.0K) |
8/15/2000 |
| This responds to a letter dated February 11, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200037021(PDF, 7.9K) |
9/7/2000 |
| This letter responds to a letter dated December 16, 1999, submitted by X's authorized representative on behalf of X, requesting a ruling under § 1362(g) of the Internal Revenue Code. |
| 200037020(PDF, 42K) |
9/7/2000 |
| As set forth below, you have requested rulings regarding the tax consequences under § 468A of the Internal Revenue Code to the Seller's qualified nuclear decommissioning fund as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the Plant and the proper allocation of basis. |
| 200037019(PDF, 20K) |
8/15/2000 |
| This letter responds to your Authorized Representative's letter dated December 29, 1999, requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file elections. |
| 200037018(PDF, 14K) |
8/15/2000 |
| This letter is in reply to your request for a ruling waiving the failure-to-pay penalty described in § 148(f)(4)(C)(x) of the Internal Revenue Code. |
| 200037017(PDF, 15K) |
8/15/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200037016(PDF, 15K) |
8/15/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200037015(PDF, 16K) |
9/7/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200037014(PDF, 16K) |
9/7/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200037013(PDF, 14K) |
8/15/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200037012(PDF, 14K) |
9/7/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200037011(PDF, 15K) |
9/7/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200037010(PDF, 15K) |
9/7/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200037009(PDF, 16K) |
8/15/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200037008(PDF, 13K) |
8/15/2000 |
| This is in response to your submission dated May 2, 2000, and prior correspondence in which you requested a ruling under § 301.9100-1 of the Procedure and Administration Regulations for an extension of time to make an election under § 2652 of the Internal Revenue Code. |
| 200037007(PDF, 17K) |
8/15/2000 |
| In a letter dated February 4, 2000, you requested rulings regarding your purchase of oil and gas properties. |
| 200037006(PDF, 29K) |
9/14/2000 |
| Whether bonds issued in Year 2 are precluded from being treated as refunding bonds due to the reorganization in Year 1 of the conduit borrower under the prior bonds. |
| 200037005(PDF, 39K) |
8/21/2000 |
| Whether the transactions resulting in the reconfiguration of P1 into an umbrella partnership real estate investment trust effectuated a disguised sale of a portion of the Original Partners interests in P1 to P3 and REIT? |
| 200037004(PDF, 54K) |
8/16/2000 |
| What is the proper time under § 461 of the Internal Revenue Code and the regulations thereunder for Taxpayer to accrue a liability for repairs made pursuant to a warranty? |
| 200037003(PDF, 29K) |
9/14/2000 |
| Whether interest is allowed on the portion of the taxpayer's overpayments of tax for Year 1 through Year 5, inclusive, credited against its Years 6 and 7 tax liabilities for the periods from September 15, Year 6, to March 15, Year 7, and September 15, Year 7, to March 15, Year 8, respectively. |
| 200037002(PDF, 24K) |
9/7/2000 |
| This letter responds to your request dated December 22, 1999, for rulings on the federal income tax consequences of a proposed transaction. |
| 200037001(PDF, 24K) |
9/7/2000 |
| This letter responds to your request dated December 22, 1999, for rulings on the federal income tax consequences of a proposed transaction. |
| 200036051(PDF, 441K) |
10/4/2001 |
| Request for rulings on your behalf under § 414(e) of the Internal Revenue Code. |
| 200036050(PDF, 199K) |
10/4/2001 |
| This letter responds to X's request dated Sept 24.1999 for a ruling that the tax on that investment income under § 4949 of the Internal Revenue Code will not apply to Xs proposed foreign investment program, as described below. |
| 200036049(PDF, 720K) |
10/4/2001 |
| Issues: (1) The establishment and operation of the Joint Operating Agreement and arrangement through T will not adversely affect the exemption of any member of G from federal income tax under § 50(c)(3) of the Code. (2) The establishment and operation of the Joint Operating Agreement and arrangement through T will not adversely affect the exemption of any member of E from federal income tax under § 501(c)(2) or 501(c)(3) of the Code. (3) The establishment and operation of the Joint Operating Agreement and arrangement through Twill not adversely affect the non-private foundation status of any member of G under § 509(a) of the Code. (4) The establishment and operation of the Joint Operating Agreement and arrangement through Twill not adversely affect the non-private foundation status of any member of E under § 509(a) of the Code. (5) Any loans, capital contributions, and/or transfers of assets, personnel and/or resources among T, any member of G participating in T and/or any member of E participating in Twill not constitute an unrelated trade or business within the meaning of § 513 of the Code. (6) The provision of management or other services among T, any member of G participating in T and/or any member of E participating in Twill not constitute an unrelated trade or business within the meaning of § 513 of the Code. |
| 200036048(PDF, 288K) |
10/4/2001 |
| This is in response to a ruling request submitted on your behalf by your authorized representative in a letter dated and supplemented by additional correspondence dated concerning distributions from a plan described in § 401(k) of the Internal Revenue Code. |
| 200036047(PDF, 257K) |
10/4/2001 |
| This is in response to the letter, as supplemented by correspondence dated, in which you, through your authorized representative, request several letter rulings under § 401(a) (9) of the Internal Revenue Code. The following facts and representations support your ruling request. |
| 200036045(PDF, 35K) |
9/7/2000 |
| Whether the terms of the trust prevent the attachment of the federal tax lien. What collection device, if any, should be used to collect from the taxpayer's interest in the trust. |
| 200036044(PDF, 10K) |
8/8/2000 |
| This is in response to a letter dated December 29, 1999, and a supplemental letter dated March 17, 2000, submitted by A's authorized representative 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. |
| 200036043(PDF, 37K) |
8/8/2000 |
| Can a Chapter 11 trustee be held personally liable under Internal Revenue Code § 6672 for failure to pay communication excise taxes collected by the estate? |
| 200036042(PDF, 7.2K) |
8/30/2000 |
| This letter responds to a letter dated November 18, 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. |
| 200036041(PDF, 11K) |
8/30/2000 |
| This letter responds to your letter dated February 25, 2000, and subsequent correspondence, submitted on behalf of Company, requesting a ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200036040(PDF, 7.8K) |
8/30/2000 |
| This responds to a letter dated May 23, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200036039(PDF, 6.0K) |
8/8/2000 |
| This letter responds to a letter dated March 10, 2000, requesting a ruling under § 1362(b)(5) of the Code that Corporation's S corporation election be effective as of Date. |
| 200036038(PDF, 13K) |
8/30/2000 |
| This responds to your March 27, 2000, letter submitted on your behalf by your representative in which Taxpayer requests a ruling (1) as to its federal excise tax liability under § 4051(a)(1) of the Internal Revenue Code in regard to its importation and sale of certain used truck trailers, and... |
| 200036037(PDF, 28K) |
8/8/2000 |
| This is in response to your letter of February 3, 2000, submitted by your authorized representative, requesting rulings under § 280G of the Internal Revenue Code. |
| 200036036(PDF, 15K) |
8/8/2000 |
| This is in response to your authorized representative's letter dated February 3, 2000, requesting rulings under § 355 of the Internal Revenue Code (the "Code") with respect to a proposed transaction. |
| 200036035(PDF, 28K) |
8/8/2000 |
| This is in response to your letter of February 3, 2000, submitted by your authorized representative, requesting rulings under § 280G of the Internal Revenue Code. |
| 200036034(PDF, 15K) |
8/8/2000 |
| This is in response to your letter of February 3, 2000, submitted by your authorized representative, requesting rulings under § 280G of the Internal Revenue Code. |
| 200036033(PDF, 22K) |
8/30/2000 |
| This letter is in response to your ruling request concerning the allocation of certain of the proceeds of the Specified Bonds for arbitrage purposes. |
| 200036032(PDF, 28K) |
8/8/2000 |
| This is in response to your letter of February 3, 2000, submitted by your authorized representative, requesting rulings under § 280G of the Internal Revenue Code. |
| 200036031(PDF, 28K) |
8/8/2000 |
| This is in response to your letter of February 3, 2000, submitted by your authorized representative, requesting rulings under § 280G of the Internal Revenue Code. |
| 200036030(PDF, 19K) |
8/8/2000 |
| This letter is in reply to a letter from you dated January 31, 2000, requesting rulings about the federal income tax consequences of a proposed transaction. |
| 200036029(PDF, 14K) |
8/8/2000 |
| This letter responds to your letter dated January 3, 2000, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200036028(PDF, 18K) |
8/30/2000 |
| This letter responds to your letter dated January 3, 2000, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200036027(PDF, 15K) |
8/8/2000 |
| This is in response to your letter of February 3, 2000, submitted by your authorized representative, requesting rulings under § 280G of the Internal Revenue Code. |
| 200036026(PDF, 15K) |
8/8/2000 |
| This is in response to your letter of February 3, 2000, submitted by your authorized representative, requesting rulings under § 280G of the Internal Revenue Code. |
| 200036025(PDF, 15K) |
8/8/2000 |
| This is in response to your letter of February 3, 2000, submitted by your authorized representative, requesting rulings under § 280G of the Internal Revenue Code. |
| 200036024(PDF, 28K) |
8/8/2000 |
| This is in response to your letter of February 3, 2000, submitted by your authorized representative, requesting rulings under § 280G of the Internal Revenue Code. |
| 200036023(PDF, 8.3K) |
8/8/2000 |
| The Ruling Letter addressed a series of transactions that included an internal distribution of Controlled stock to Distributing 2 (the "Internal Distribution") followed by a distribution of the Controlled stock to the public shareholders of Distributing 2 (the "External Distribution"). |
| 200036022(PDF, 25K) |
8/8/2000 |
| To which party should the Internal Revenue Service issue the statutory notice of deficiency? |
| 200036021(PDF, 19K) |
8/30/2000 |
| This is in response to your submission dated February 4, 2000, and supplementary submissions requesting on behalf of Taxpayer certain rulings regarding the tax treatment of certain amounts received in connection with annuity policies issued by Taxpayer and whether the proposed contract qualifies as an immediate annuity for purposes of § 72 of the Internal Revenue Code . |
| 200036020(PDF, 21K) |
8/8/2000 |
| This is in reference to your April 24, 2000, correspondence, and prior submissions, in which you requested rulings regarding the effect of the proposed transfer of assets held in trust to a newly-created entity for federal income, gift, and generation-skipping transfer tax purposes. |
| 200036019(PDF, 15K) |
8/8/2000 |
| This is in response to your letter dated February 1, 2000, and prior correspondence, submitted on behalf of the trustees and trust beneficiaries requesting income tax and generation-skipping transfer tax rulings concerning the merger of identical trusts. |
| 200036018(PDF, 14K) |
8/8/2000 |
| This responds to your letter dated December 15, 1999, and subsequent correspondence, submitted on behalf of G requesting an extension of time pursuant to §301.9100-3(a) of the Procedure and Administration Regulations to file an election for G to be classified as a partnership for federal tax purposes under § 301.7701-3(c). |
| 200036017(PDF, 37K) |
8/30/2000 |
| Whether A may apply § 1341 of the Internal Revenue Code where damages were paid in settlement to C and others for a liability resulting from understated rents and royalties. |
| 200036016(PDF, 48K) |
8/30/2000 |
| Whether Company A can utilize the Treasury Regulation §1.955A-3(c)(2)(ii) group excess deduction provision of the related group election to reduce its overall taxable income for tax years in which it did not file a written election. |
| 200036015(PDF, 77K) |
9/7/2000 |
| Whether, for customs purposes, royalties or license fees paid by a U.S. importer to a foreign related party were properly taken into account in the dutiable value of the imported merchandise, as elements of the "price actually paid or payable for the merchandise when sold for exportation to the United States," pursuant to 19 U.S.C. §§ 1401a(b)(1) and (b)(4)(A), or, alternatively, as proceeds of resale that "accrue[d] directly or indirectly to the seller," pursuant to 19 U.S.C. § 1401a(b)(1)(E). |
| 200036014(PDF, 10K) |
8/30/2000 |
| This is in reply to your request for a ruling under § 453 of the Internal Revenue Code and § 15a.453-1(c)(7) of the Temporary Income Tax Regulations that W, a corporation which elected to be taxed as a small business corporation, be allowed to use an alternative method of basis recovery to report the contingent payment sale of one of its lines of business. |
| 200036013(PDF, 27K) |
8/30/2000 |
| This is in response to your letter dated November 16, 1999, in which you requested rulings concerning the federal gift, estate, and generation-skipping transfer tax consequences of a judgment and order entered by a court in a proceeding for the construction of the provisions of Decedent's will. |
| 200036012(PDF, 37K) |
8/30/2000 |
| Whether any part of the corpus of the grantor retained annuity trust (GRAT) is includable in Decedent's gross estate under Internal Revenue Code §§ 2036 and/or 2039. |
| 200036011(PDF, 23K) |
8/30/2000 |
| Whether Internal Revenue Code § 1341(a) applies to payments made by A to settle various actions brought on behalf of the United States Government for alleged overcharges and violations of federal statutes including the False Claims Act. |
| 200036010(PDF, 26K) |
8/8/2000 |
| As set forth below, you have requested rulings regarding the tax consequences under § 468A of the Internal Revenue Code to the Seller's qualified nuclear decommissioning fund as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the Plant. |
| 200036009(PDF, 20K) |
8/30/2000 |
| Whether an accrual basis taxpayer may deduct at year end, the amount of its claim reserve account consisting of an estimate of its liability for services rendered to enrollees prior to the end of the year, but for which claims have not been filed. |
| 200036008(PDF, 11K) |
8/8/2000 |
| We received the July 1, 1999, letter and later submissions requesting a ruling on the application of the generation-skipping transfer tax provisions of Chapter 13 of the Internal Revenue Code to a construction of a trust. |
| 200036007(PDF, 28K) |
8/8/2000 |
| This letter responds to a letter dated June 22, 1999, and subsequent correspondence, submitted on behalf of P by its authorized representative, requesting rulings under § 29 and 702 of the Internal Revenue Code. |
| 200036006(PDF, 20K) |
8/30/2000 |
| Whether settlement payments made by A entitle it to use the special computation of tax set forth in Internal Revenue Code § 1341. |
| 200036005(PDF, 25K) |
8/30/2000 |
| This is to notify you, in accordance with § 8.07(2)(a) of Rev. Proc. 2000-1, 2000-1 I.R.B. 4, 33, that Taxpayer 1 and Taxpayer 2 (referred to collectively as "Taxpayers") have withdrawn their applications for a change in accounting method. |
| 200036004(PDF, 25K) |
8/30/2000 |
| This is to notify you, in accordance with § 8.07(2)(a) of Rev. Proc. 2000-1, 2000-1 I.R.B. 4, 33, that Taxpayer 1 and Taxpayer 2 (referred to collectively as "Taxpayers") have withdrawn their applications for a change in accounting method. |
| 200036003(PDF, 24K) |
8/30/2000 |
| In a technical advice memorandum ("TAM") issued by the Assistant Chief Counsel (Corporate), the Service concluded that the end result test under the step transaction doctrine is an appropriate test to determine whether to treat a series of cash distributions as taxable "boot" in a § 351 transaction. |
| 200036002(PDF, 29K) |
8/8/2000 |
| Whether the end result test under the step transaction doctrine is an appropriate test to determine whether to treat cash distributions from a wholly owned subsidiary corporation ("Subsidiary") to its parent corporation ("Taxpayer") of $e, $j, and $d as taxable "boot" in a 351 transaction? |
| 200036001(PDF, 11K) |
8/8/2000 |
| Who is liable for the excise tax imposed by § 4001 of the Internal Revenue Code in the four party vehicle lease transaction described below and when is that liability incurred? If Taxpayer is liable for the excise tax, what is included in the tax base? |
| 200035036(PDF, 354K) |
10/4/2001 |
| In a letter dated October 15, 1999, you requested a ruling concerning the federal income tax treatment of certain contributions to System B under § 414(h) (2) of the Internal Revenue Code. |
| 200035035(PDF, 353K) |
10/4/2001 |
| In a letter dated October 15, 1999, you requested a ruling concerning the federal income tax treatment of certain contributions to Plan X under § 414th) (2) of the Internal Revenue Code. |
| 200035034(PDF, 323K) |
10/4/2001 |
| This is in reply to your rulings request of October 22, 1999, requesting rulings as to P's proposed transfer of one-half of its assets to T pursuant to § 507lb)l21 of the Internal Revenue Code. |
| 200035033(PDF, 321K) |
10/2/2001 |
| This is in response to a ruling request dated November l-5,1999, concerning the pick up of certain employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200035032(PDF, 10K) |
8/4/2000 |
| This is in response to your letter dated April 24, 2000, 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. |
| 200035031(PDF, 12K) |
8/4/2000 |
| We respond to your letter dated January 31, 2000, requesting rulings concerning the federal income tax consequences of a proposed transaction. |
| 200035030(PDF, 13K) |
8/4/2000 |
| You have requested a ruling that Funds be granted an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an election under § 855 of the Internal Revenue Code for Funds' tax year ending Date 1. |
| 200035029(PDF, 23K) |
8/23/2000 |
| This responds to your letter dated December 27, 1999, in which you requested a ruling and closing agreement that premiums received by Taxpayer on policies of insurance or reinsurance of United States risks are exempt from the insurance excise tax imposed by § 4371 of the Internal Revenue Code pursuant to the Income Tax Convention between the United States and the Government of Ireland (the "Convention"). |
| 200035028(PDF, 13K) |
8/4/2000 |
| This letter responds to a letter from your authorized representative dated February 3, 2000, submitted on behalf of Company, requesting a ruling under § 1362(f) of the Internal Revenue Code that the termination of Company's S corporation election was inadvertent. |
| 200035027(PDF, 18K) |
8/22/2000 |
| This is in response to your representative's letter dated June 17, 1999, as amended by letters dated March 21, 2000 and April 14, 2000, requesting rulings regarding the taxability of income received by A under the Income Tax Treaty Between Canada and the United States (the "Treaty"). |
| 200035026(PDF, 8.1K) |
8/4/2000 |
| This responds to a letter dated January 4, 2000, together with subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200035025(PDF, 22K) |
8/23/2000 |
| You have requested a ruling, on behalf of the Issuer, that a proposed new bond issue (the "New Bonds") will be treated as a current refunding issue, refunding the Y Bonds, within the meaning of § 1.150-1(d) of the Income Tax Regulations and § 1313(a) of the Tax Reform Act of 1986, as amended (the "Act"). |
| 200035024(PDF, 36K) |
9/1/2000 |
| You raised the question of how to determine the Treasury Regulation § 1.861-8 expenses associated with the excluded component. |
| 200035023(PDF, 7.4K) |
8/4/2000 |
| This letter responds to a letter dated January 27, 2000, and subsequent correspondence, written on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200035022(PDF, 15K) |
8/22/2000 |
| This letter responds to your January 19, 2000 request for rulings regarding certain federal income tax consequences of a proposed transaction. |
| 200035021(PDF, 25K) |
8/4/2000 |
| Whether the cost of removal of asbestos incident to the repair of production plants and machinery is deductible as a current expense or should be capitalized under Internal Revenue Code § 263. |
| 200035020(PDF, 45K) |
8/23/2000 |
| Whether the information provided supports a determination that the transaction enabled the parties to exploit the difference between tax-exempt and taxable rates. Whether the remarketing of the bonds resulted in a reissuance. |
| 200035019(PDF, 41K) |
8/4/2000 |
| For purposes of § 902 of the Internal Revenue Code, where FSub settled a year 4 foreign tax controversy by paying additional foreign income tax in year 9, must FSub adjust its pools of post-1986 undistributed earnings and post-1986 foreign income taxes in year 9, or may USParent recompute those pools for year 4 and claim a refund of U.S. tax attributable to additional deemed-paid foreign tax credits based on the recomputed year 4 pools? |
| 200035018(PDF, 45K) |
8/23/2000 |
| Whether characterizing certain payments received by taxpayer in connection with five contracts for the purchase of goods as advance rental for shelf space or as consideration for exclusivity over the period of the agreement will adversely affect the Service's position on the tax treatment of similar payments in other areas. |
| 200035017(PDF, 13K) |
8/23/2000 |
| This responds to your letter on Company's behalf dated February 3, 2000, as well as subsequent correspondence, requesting a ruling under § 1362(f) of the Internal Revenue Code that Company's S corporation election was inadvertently invalid. |
| 200035016(PDF, 25K) |
8/4/2000 |
| This letter responds to your letter dated November 29, 1999, submitted on behalf of Partnership, requesting a private letter ruling under § 42(h)(4)(B) and § 42(i)(2)(A) of the Internal Revenue Code. |
| 200035015(PDF, 35K) |
9/1/2000 |
| Whether there is a statute of limitations on assessment of the Internal Revenue Code § 6702 frivolous return penalty where what purports to be an amended return (claim for refund), later determined to be frivolous, is filed after a valid original return? |
| 200035014(PDF, 15K) |
8/4/2000 |
| This letter responds to a November 19, 1999 request and subsequent correspondence submitted by the authorized representatives of Trust concerning the federal tax consequences of a proposed division of Trust. |
| 200035013(PDF, 6.2K) |
8/4/2000 |
| This is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer, requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending D1, to a taxable year ending D2, effective D3. |
| 200035012(PDF, 7.8K) |
8/22/2000 |
| Letter ruling 199916011 concluded that the Plan satisfied the requirements of § 62(c) of the Internal Revenue Code and that amounts paid under the Plan could be treated as paid under a reimbursement or other expense allowance arrangement in accordance with § 62(a)(2)(A). |
| 200035011(PDF, 8.2K) |
8/4/2000 |
| This letter responds to the ruling request dated March 27, 2000, that was submitted by your representative and which requests relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200035010(PDF, 48K) |
8/4/2000 |
| Whether the taxpayer may mark to market its unbilled receivables (anticipated income) under Internal Revenue Code § 475. Whether I.R.C. § 751(c) is applicable to the determination of whether the taxpayer's unbilled receivables represent indebtedness. |
| 200035009(PDF, 22K) |
8/4/2000 |
| This is in response to a request for rulings dated June 26, 1998, and subsequent correspondence, submitted on behalf of the Company by its authorized representatives. Rulings are requested regarding the income tax consequences relating to the exercise of participation options as more fully described below. |
| 200035008(PDF, 32K) |
8/4/2000 |
| Issuer adopted Basic Resolution b to establish a common bond fund (the "Bond Fund") in order to (a) consolidate the terms and conditions of its various bond resolutions and funds, (b) adjust the maturities of revenue bonds to coincide with the receipt of revenues available for their payment, and (c) to reduce the debt service requirements of such bonds. |
| 200035007(PDF, 17K) |
8/4/2000 |
| Whether benefits provided to tribal members through various programs administered by the education department of the tribal government of Tribe are taxable to the recipients and subject to income tax withholding under § 3402(r) of the Internal Revenue Code? |
| 200035006(PDF, 31K) |
8/4/2000 |
| Is Trust considered a separate entity from Taxpayer in determining material participation in Partnership for purposes of applying the passive activity loss and credit limitations of Internal Revenue Code § 469? |
| 200035005(PDF, 31K) |
8/4/2000 |
| Whether the exchange of Federal Communications Commission (FCC) radio broadcast station licenses (radio licenses) for an FCC television broadcast station license (television license) is a like kind exchange subject to the nonrecognition rules under § 1031 of the Internal Revenue Code. |
| 200035004(PDF, 8.8K) |
8/4/2000 |
| This replies to a letter dated April 3, 2000, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement described in § 1.1503- 2(g)(2) with respect to losses incurred by Subsidiary and Entity #1 in the tax year ended on Date A; |
| 200035003(PDF, 30K) |
8/22/2000 |
| Is the transfer of property by an organization described in § 501(c)(3) of the Code to a liquidating trust a taxable transaction? |
| 200035002(PDF, 74K) |
9/1/2000 |
| Whether G are property which is similar or related in service or use to C for purposes of deferring gain under Internal Revenue Code § 1033. |
| 200035001(PDF, 32K) |
8/23/2000 |
| This letter responds to your November 23, 1999 request for rulings on certain federal income tax consequences of a proposed series of transactions. |
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