2001 Chief Counsel's
Written Determinations
200120000 to 200124999
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.
| 200124030(PDF, 79K) |
6/18/2001 |
| This letter is in response to a ruling request dated July 13, 2000, submitted on your behalf by your authorized representative, as supplemented by correspondence dated February 9, and February 28, 2001, in which you request rulings under § 403(b), 401(a), and 2518(b) of the Internal Revenue Code. |
| 200124029(PDF, 40K) |
6/17/2001 |
| This letter responds to the request of counsel for X (the Estate), dated June 23, 2000, as supplemented, and amended, by letters dated October 25, November 6, November 13, and March 19, 2001, for rulings regarding the issue of self-dealing under § 4941 of the Internal Revenue Code. |
| 200124028(PDF, 35K) |
6/16/2001 |
| This is in response to a letter dated December 16, 2000, submitted on your behalf by your authorized representative requesting a letter ruling regarding your election under § 242(b)(2) of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). The following facts and representations were submitted on your behalf. |
| 200124027(PDF, 39K) |
6/15/2001 |
| This is in response to your letter dated November 27, 2000, in which you requested certain rulings with respect to a proposed transfer of assets from B to C. |
| 200124026(PDF, 35K) |
6/14/2001 |
| This is in response to your letter dated November 27, 2000, in which you requested certain rulings with respect to a proposed transfer of assets from 6 to C. |
| 200124025(PDF, 62K) |
6/13/2001 |
| This letter is in response to a ruling request dated July 10, 2000, as supplemented by correspondence dated October 12, 2000, as supplemented by letters dated December 8, 2000, December 20, 2000, and February 7, 2001, submitted on your behalf by your authorized representative, concerning the church plan status of Plan X under § 414(e) of the Internal Revenue Code . |
| 200124024(PDF, 43K) |
6/12/2001 |
| Issues: (1) As of the date of the filing of the notice of termination of private foundation status pursuant to § 507(a)(l) of the Code and § 1.507-1(b) of the Regulations, the foundation will be deemed to have ceased to exist for purposes of Subchapter F of Chapter 1 and Chapter 42 and to have been reconstituted as a newly organized entity that will not qualify as an organization described in § 501 (c)(3). (2) If the foundation terminates its status as a private foundation under § 507(a)(l) of the Code, the Service will exercise its authority under § 507(g) to abate the tax imposed by § 507(c). (3) After the date of the filing of the notice under § 507(a)(l) of the Code, Chapter 42 will not apply to the foundation. Accordingly, the sale of assets of the foundation as described herein will not be subject to tax on self-dealing under § 4941. (4) After the date of filing the notice under § 507(a)(l) of the Code, the foundation will not be required to file annual information returns pursuant to § 6033. |
| 200124023(PDF, 118K) |
6/11/2001 |
| By letter dated July 20, 2000, 1 and C requested certain rulings under § 507, 4940, 4941, 4942, 4944 and 4945 of the Internal Revenue Code, in connection with a proposed transaction. |
| 200124022(PDF, 49K) |
6/10/2001 |
| This is in reference to a ruling request submitted by counsel for X regarding the federal income tax consequences of certain proposed transactions (the "Transactions"). |
| 200124021(PDF, 42K) |
6/9/2001 |
| This is in response to letters from your authorized representative requesting a series of rulings on your behalf regarding the tax consequences associated with the transactions described below. |
| 200124020(PDF, 22K) |
6/15/2001 |
| Issues: (1) Whether the Internal Revenue Service is required, pursuant to either § 6331(k) of the Internal Revenue Code or the Commissioner's policy on withholding collection while an offer in compromise is pending, to release a levy on Social Security retirement benefits which was made prior to the offer becoming pending with the Service. (2) Whether property levied prior to submission of an offer in compromise but received after the offer became pending must be returned to the taxpayer. |
| 200124019(PDF, 19K) |
6/15/2001 |
| This Chief Counsel Advice responds to your request for assistance dated February 7, 2001, raising questions regarding the tax treatment of payments made to individuals pursuant to the subject settlement. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200124018(PDF, 18K) |
6/15/2001 |
| Issue: Whether the PALS can sell real property in a lien foreclosure action, either upon the court's order or after appointment by the U.S. Marshal. |
| 200124017(PDF, 26K) |
6/15/2001 |
| This responds to your request for assistance in reviewing Federal Insurance Contributions Act (FICA) tax refund claims and adjustments filed by school districts within the State that maintains the retirement system that received a favorable ruling from the Service in private letter ruling 102485-98 ("the ruling"). |
| 200124016(PDF, 14K) |
6/15/2001 |
| Request for a ruling that Taxpayer be granted an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an election to be treated as a real estate mortgage investment conduit (REMIC) under § 860D of the Internal Revenue Code. |
| 200124015(PDF, 12K) |
6/15/2001 |
| Request for a ruling that Taxpayer be granted an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an election to be treated as a real estate mortgage investment conduit (REMIC) under § 860D of the Internal Revenue Code. |
| 200124014(PDF, 23K) |
6/15/2001 |
| Issues: (1) What is the appropriate start date for the accrual of interest on income tax deficiencies for taxable Years 1, 3, and 4? (2) Are the deficiencies subject to interest at the tax-motivated interest rate under § 6621 of the Internal Revenue Code? |
| 200124013(PDF, 5.7K) |
6/15/2001 |
| This letter responds to a letter dated December 12, 2000, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200124012(PDF, 35K) |
6/15/2001 |
| We received your letter dated January 12, 2001, requesting rulings under § 2601 of the Internal Revenue Code. |
| 200124011(PDF, 12K) |
6/15/2001 |
| Issue: May an income tax return for A's 1996 tax year be filed now with an election to exclude gain on the sale of a principal residence under § 121 of the Internal Revenue Code, as in effect in 1996? |
| 200124010(PDF, 10K) |
6/15/2001 |
| This letter responds to a letter dated March 21, 2000, and subsequent correspondence written on behalf of Trust, that a proposed transfer of Trust's principal to certain charitable organizations will not affect Trust's assumed qualification as a charitable remainder unitrust under § 664 of the Internal Revenue Code and the applicable regulations. |
| 200124009(PDF, 23K) |
6/15/2001 |
| This letter is in reply to your letter dated October 12, 2000 requesting rulings about the federal income tax consequences of a proposed transaction. |
| 200124008(PDF, 23K) |
6/15/2001 |
| This Field Service Advice responds to the first issue raised in your memorandum dated August 7, 2000. Field Service Advice is not binding on Examination or Appeals and is not a final case determination. |
| 200124007(PDF, 11K) |
6/15/2001 |
| Request an extension of time under § 301.9100-1 through § 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200124006(PDF, 29K) |
6/15/2001 |
| This is in response to the October 13, 2000 letter and other correspondence requesting rulings on the application of § 2041 and 2601 of the Internal Revenue Code to the proposed transaction. |
| 200124005(PDF, 24K) |
6/15/2001 |
| Issue: Whether in an appeal of a determination under § 6330, the taxpayer may introduce at trial new testimonial and documentary evidence to challenge the existence or amount of his underlying tax liability when he did not produce that evidence before or during the collection due process hearing. |
| 200124004(PDF, 4.7K) |
6/15/2001 |
| 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. |
| 200124003(PDF, 35K) |
7/15/2001 |
| Issue: Whether the FICA tax adjustments proposed for years B and C should be maintained? |
| 200124002(PDF, 51K) |
6/15/2001 |
| Issues: (1) Whether use of the Borrower's Minor League franchise by the Affiliate constitutes private business use under § 141(b)(1) of the Internal Revenue Code? (2) If the Affiliate's use of the Borrower's Minor League franchise constitutes private business use, what is the amount of private business use that results from that use? (3) Whether the Affiliate's use of the Stadium (hereinafter defined) constitutes private business under § 141(b)(1)? |
| 200124001(PDF, 17K) |
6/15/2001 |
| This is in response to your request for certain rulings concerning the distributions X will make to eligible policyholders in connection with its conversion from a mutual life insurance company to a stock life insurance company. |
| 200123074(PDF, 70K) |
6/8/2001 |
| This letter is in response to a request for a ruling request dated September 14, 2000, as supplemented by correspondence dated October 18, 2000, and February 21, 2001, which was submitted on your behalf by your authorized representative, concerning an arrangement described under § 403(b)(l) of the internal Revenue Code . |
| 200123073(PDF, 25K) |
6/7/2001 |
| This is in reference to your letter of December 7, 2000, requesting a ruling that your grants to individuals are not taxable expenditures within the meaning of § 4945 of the Internal Revenue Code. |
| 200123072(PDF, 43K) |
6/6/2001 |
| This is in reply to your letters dated April 9, 1999, and September 28, 2000, requesting rulings under § 501 (c)(3) and 4941 of the internal Revenue Code. |
| 200123071(PDF, 44K) |
6/5/2001 |
| This letter is in response to your letter dated July 17, 2000, and subsequent correspondence requesting rulings under § 501 (c)(3), 509(a)(2), 507, 4941, 4942, 4944, and 4945 of the Internal Revenue Code. |
| 200123070(PDF, 80K) |
6/4/2001 |
| This is in response to the request for letter ruling submitted on your behalf by your authorized representative, L supplemented by correspondence and in which you request a series of letter rulings with respect to § 401(a)(9) and 40&a)(6) of the Internal Revenue Code. The following facts and representations support your ruling requests. |
| 200123069(PDF, 47K) |
6/3/2001 |
| This letter is in response to your letter dated July 17, 2000, and subsequent correspondence requesting rulings under § 501 (c)(3), 509(a)(Z), 507,4941,4942,4944, and 4945 of the Internal Revenue Code. |
| 200123068(PDF, 51K) |
6/2/2001 |
| This letter constitutes notice that 5 412(f)(l) of the Internal Revenue Code and 9 304(b)(l) of the Employee-Retirement Income Security Act of 1974, as amended (ERISA) do not apply to the amendment described below with respect to the above-named defined benefit pension plan. This ruling is directed only to the taxpayer that requested it. § 6110(k)(3) of the Internal Revenue Code provides that it may not be used or cited by others as precedent. |
| 200123067(PDF, 62K) |
6/1/2001 |
| This letter concerns the request of November 27, 1996 made to our office, and resubmitted to our office on January 5, 1999, for waivers of the minimum funding standard for the above-named money purchase plan for the plan years ending December 31, 1995 and 1996. Furthermore, this letter constitutes notice that (1) the request for a waiver of the minimum funding standard for the plan year ending December 31,1995 will not be considered because it was made after the statutory deadline for such a request, and (2) the request for a waiver of the minimum funding standard for the plan year ending December 31, 1996 has been granted subject to the following conditions: |
| 200123066(PDF, 55K) |
5/31/2001 |
| This is in response to your ruling request dated November 30, 1999, as supplemented by correspondence dated June 14, 2000, and September 22, 2000, made on your behalf by your authorized representative, concerning the pick up of employee contributions under Plan X pursuant to § 414(h) (2) of the Internal Revenue Code . |
| 200123065(PDF, 60K) |
5/30/2001 |
| This is in response to M's request for a ruling that it is a qualified State tuition program, operating as a savings program, exempt from federal income tax under § 529 of the Internal Revenue Code (hereafter "Code"). |
| 200123064(PDF, 31K) |
5/29/2001 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan, waivers of the 100 percent excise tax under g 4971(b) of the Internal Revenue code have been granted for the tax years ended August 31, 1998-2001. |
| 200123063(PDF, 26K) |
6/8/2001 |
| Issue: Do the facts, as developed or could reasonably be developed within a short time frame, sufficiently support bringing an erroneous refund suit against an individual more than two years after such refund was made, where the individual submitted a check noted with a partnership EIN, which resulted in the check being posted to a partnership account and the amount thereof refunded to the partnership, but for which, upon his request, he was credit with a payment in the amount of the check, with the portion exceeding his outstanding liabilities refunded to him with interest? |
| 200123062(PDF, 134K) |
6/8/2001 |
| The court of appeals in United States v. Bisbee, 2001 U.S. App. LEXIS 6017 (8 th Cir. Apr. 9, 2001) awarded attorneys' fees to a defendant, finding the Service's legal position in assessing the Trust Fund Recovery Penalty lacked a reasonable basis in fact. |
| 200123061(PDF, 16K) |
6/8/2001 |
| On June 15, 2000, we issued a memorandum (see attached) in reference to consent dividends paid by a personal holding company to its shareholder. Specifically, the taxpayer declared a consent dividend to its shareholders under § 565 of the Internal Revenue Code. |
| 200123060(PDF, 271K) |
8/17/2001 |
| You have asked for our review and comments with respect to a form "Hello" letter that Las Vegas Appeals intends to use in Collection Due Process (CDP) cases in which only frivolous or constitutional arguments are raised. |
| 200123059(PDF, 33K) |
6/8/2001 |
| Issue: Whether the Service must request the taxpayer to amend Form 656 when a taxpayer has submitted an offer in compromise checking the box indicating doubt as to collectability and the service has decided to accept the offer on the basis of effective tax administration? |
| 200123058(PDF, 6.3K) |
6/8/2001 |
| This responds to your letter dated November 13, 2000, submitted on behalf of X requesting rulings under the Internal Revenue Code. |
| 200123057(PDF, 14K) |
6/8/2001 |
| This in response to your letter requesting a ruling that, based on all the facts and cInternal Revenue Codeumstances, C does not have any role or relationship with B, the qualified user, that substantially limits B's ability to exercise its rights, including cancellation rights, under the professional service agreement. |
| 200123056(PDF, 8.3K) |
6/8/2001 |
| Requesting a ruling 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. |
| 200123055(PDF, 14K) |
6/8/2001 |
| Rulings were requested concerning the federal gift and estate tax consequences of a court order reforming Trust 1 and Trust 2. |
| 200123054(PDF, 18K) |
6/8/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200123053(PDF, 10K) |
6/8/2001 |
| Request for rulings concerning the federal income tax consequences of a proposed transaction. |
| 200123052(PDF, 11K) |
6/8/2001 |
| This responds to the letter dated December 18, 2000, and subsequent correspondence, submitted on behalf of X requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200123051(PDF, 5.7K) |
6/8/2001 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200123050(PDF, 6.1K) |
6/8/2001 |
| This responds to your representative's letter dated November 29, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200123049(PDF, 6.9K) |
6/8/2001 |
| This letter responds to your December 26, 2000 request for a private letter ruling, along with subsequent correspondence, submitted on behalf of LP, requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200123048(PDF, 11K) |
6/8/2001 |
| Requesting, an extension of time under § 301.9100-1 through § 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200123047(PDF, 53K) |
6/8/2001 |
| Denial of request for change in accounting method. |
| 200123046(PDF, 63K) |
6/8/2001 |
| 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. |
| 200123045(PDF, 15K) |
6/8/2001 |
| Requesting a ruling under § 2041 of the Internal Revenue Code. |
| 200123044(PDF, 6.2K) |
6/8/2001 |
| This responds to a letter dated January 16, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200123043(PDF, 14K) |
6/8/2001 |
| Requesting an extension of time under § 301.9100-1 through § 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200123042(PDF, 18K) |
6/8/2001 |
| You have requested rulings regarding the tax consequences to the Taxpayer and its qualified nuclear decommissioning funds. |
| 200123041(PDF, 12K) |
6/8/2001 |
| This letter responds to your request dated March 10, 2000, and subsequent submissions, submitted by your authorized legal representative on behalf of the Taxpayer. The request is for a revised schedule of ruling amounts under § 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund (the "Fund") under the jurisdiction of Commission A. |
| 200123040(PDF, 12K) |
6/8/2001 |
| Request dated March 10, 2000, and subsequent submissions, submitted by your authorized legal representative on behalf of the Taxpayer. The request is for a revised schedule of ruling amounts under § 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund (the "Fund") under the jurisdiction of Commission A. |
| 200123039(PDF, 12K) |
6/8/2001 |
| The request is for a revised schedule of ruling amounts under § 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund (the "Fund") under the jurisdiction of Commission A. |
| 200123038(PDF, 13K) |
6/8/2001 |
| Requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 ( Code ) 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. |
| 200123037(PDF, 8.6K) |
6/8/2001 |
| Requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 ( Code ) 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. |
| 200123036(PDF, 8.2K) |
6/8/2001 |
| Requesting a ruling that the rental income received by Company from the Property is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200123035(PDF, 16K) |
6/8/2001 |
| Requesting certain rulings regarding the formation of a limited liability company ( LLC ). |
| 200123034(PDF, 18K) |
6/8/2001 |
| This is in response to your letter dated February 28, 2001, and prior correspondence, in which you requested rulings regarding §§ 2503 and 2033 of the Internal Revenue Code. |
| 200123033(PDF, 33K) |
6/8/2001 |
| Requesting rulings that certain income will be patronage-sourced income within the meaning of subchapter T of the Internal Revenue Code. |
| 200123032(PDF, 16K) |
6/8/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200123031(PDF, 5.7K) |
6/8/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200123030(PDF, 10K) |
6/8/2001 |
| This letter responds to your December 21, 2000 request for a supplement to our letter ruling dated June 30, 1999 (the Original Ruling ) (PLR 199939040) and supplemented by letter ruling dated May 23, 2000 (the First Supplemental Ruling ) (PLR 200033042). |
| 200123029(PDF, 4.7K) |
6/8/2001 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending to a taxable year ending X, effective Y. |
| 200123028(PDF, 4.6K) |
6/8/2001 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending, to a taxable year ending A, effective X. |
| 200123027(PDF, 4.7K) |
6/8/2001 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending, to a taxable year ending A, effective B. |
| 200123026(PDF, 23K) |
6/8/2001 |
| This letter responds to the request of Taxpayer, dated March 13, 2000, for a revised schedule of ruling amounts in accordance with § 1.468A-3(i) of the Income Tax Regulations. |
| 200123025(PDF, 8.9K) |
6/8/2001 |
| This is in response to a request submitted by you on behalf of the Authority for an extension of time under § 301.9100-1 of the Procedure and Administrative Regulations to file Form 8328 in order to make a carryforward election under § 146(f) of the Internal Revenue Code. |
| 200123024(PDF, 45K) |
6/8/2001 |
| Issue: Whether Taxpayer is required to reduce the amount of its life insurance reserves under § 807(d)(1) of the Internal Revenue Code by ceded reinsurance in cases where the reinsured risks are ceded on a yearly renewable term (YRT) basis and the amount of those life insurance reserves is based on the net surrender values of the reinsured contracts? |
| 200123023(PDF, 4.9K) |
6/8/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200123022(PDF, 6.1K) |
6/8/2001 |
| Request for a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200123021(PDF, 7.4K) |
6/8/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation status will be effective as of the taxable year beginning D1. |
| 200123020(PDF, 11K) |
6/8/2001 |
| Request for a supplement to our prior letter ruling dated June 20, 1996 (the Prior Letter Ruling ) (PLR 9637052). |
| 200123019(PDF, 6.3K) |
6/8/2001 |
| This responds to the letter dated December 15, 2000, submitted by your representative on behalf of X, requesting relief under §1362(b)(5) of the Internal Revenue Code. |
| 200123018(PDF, 9.6K) |
6/8/2001 |
| Issue: Is Taxpayer liable for the excise tax imposed by § 4471 of the Internal Revenue Code under the cInternal Revenue Codeumstances described below? |
| 200123017(PDF, 5.8K) |
6/8/2001 |
| This responds to the letter dated January 7, 2001, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200123016(PDF, 6.2K) |
6/8/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200123015(PDF, 8.2K) |
6/8/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200123014(PDF, 15K) |
6/8/2001 |
| This is in reference to your October 10, 2000 correspondence, and prior submissions, requesting rulings regarding the effect of the proposed judicial modification of the trust instrument for federal generation-skipping transfer tax purposes. |
| 200123013(PDF, 15K) |
6/8/2001 |
| This is in reference to your October 10, 2000 correspondence, and prior submissions, requesting rulings regarding the effect of the proposed judicial modification of the trust instrument for federal generation-skipping transfer tax purposes. |
| 200123012(PDF, 15K) |
6/8/2001 |
| This is in reference to your October 10, 2000 correspondence, and prior submissions, requesting rulings regarding the effect of the proposed judicial modification of the trust instrument for federal generation-skipping transfer tax purposes. |
| 200123011(PDF, 49K) |
6/8/2001 |
| Requesting rulings under §§ 351 and 355 of the Internal Revenue Code (the Code ) with respect to a proposed series of transactions. |
| 200123010(PDF, 17K) |
6/8/2001 |
| Issue: Whether the person authorized to act on behalf of a partnership in a Power of Attorney, Form 2848, that was signed by the tax matters partner (TMP) of the partnership on behalf of the partnership is authorized to execute a Consent to Extend the Time to Assess Tax Attributable to Items of a Partnership, Form 872-P, on behalf of the partnership. |
| 200123009(PDF, 27K) |
6/8/2001 |
| Issues: (1) Whether the Service can make an assessment of a deficiency and restricted interest after the statute of limitations has expired. (2) Whether amounts paid to the Service by Taxpayer constitute advance payments or deposits. (3) Whether the Service is required to refund the payments received from Taxpayer both prior to and after the running of the statute of limitations. |
| 200123008(PDF, 37K) |
6/8/2001 |
| This Field Service Advice responds to your memorandum dated March 29, 2000. Field Service Advice is not binding on Examination or Appeals and is not a final case determination. |
| 200123007(PDF, 4.7K) |
6/8/2001 |
| Request for permission to change its accounting period, for federal income tax purposes, from a taxable year ending X, to a taxable year ending Y, effective. |
| 200123006(PDF, 17K) |
6/8/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200123005(PDF, 4.7K) |
6/8/2001 |
| 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. |
| 200123004(PDF, 11K) |
6/8/2001 |
| This letter responds to a letter from your authorized representative dated August 25, 2000, requesting a ruling on the proper federal income tax treatment of certain disability retirement benefits paid to members of the Plan under the Statute. |
| 200123003(PDF, 52K) |
6/8/2001 |
| You argue that the exception found in Treasury Regulation § 301.6323(g)-1(a)(3)(i) requires a different conclusion. |
| 200123002(PDF, 13K) |
6/8/2001 |
| Issue: Are amounts paid by Y to X, a limited liability company, exempt from the tax imposed by § 4261 of the Internal Revenue Code as payments between members of an affiliated group for purposes of § 4282? |
| 200123001(PDF, 12K) |
6/8/2001 |
| This responds to a request dated May 15, 2000, submitted by your authorized representative for a ruling regarding whether services performed in the employ of Taxpayer by students who are enrolled and regularly attending classes at University are excepted from employment pursuant to § 3121(b)(10)(B) of the Internal Revenue Code for purposes of the Federal Insurance Contributions Act (FICA). |
| 200122051(PDF, 39K) |
5/28/2001 |
| This is in reply to your letter of March 30, 2000, as modified by your letter of November 27, 2000, regarding the transfer of H's assets to another voluntary employees' beneficiary association (VEBA) sponsored by you. |
| 200122050(PDF, 57K) |
5/27/2001 |
| This is in response to the letter, submitted by your authorized representative on your behalf, as supplemented by correspondence dated in which you request relief under § 30 1.9 100-3 of the Procedure and Administration Regulations. The following facts and representations support your ruling request. |
| 200122049(PDF, 35K) |
5/26/2001 |
| This is in reply to your letter of May 22, 2000, requesting advance approval of your scholarship grant making procedures pursuant to the provisions of § 4945 of the Internal Revenue Code. |
| 200122048(PDF, 47K) |
5/25/2001 |
| This letter is in response to your request on behalf of Taxpayer K, dated August 17, 2000, in which you asked for a ruling as to whether certain proposed distributions from an individual retirement account (IRA B) owned by Taxpayer K are part of a series of substantially equal periodic payments and are therefore not subject to the 10 percent additional tax imposed on premature distributions under § 72(t) of the Internal Revenue Code (Code). The ruling request was amended by you in telephone calls with of our office on November 15, 2000, January 31, 2001, and on February 1, 2001, to clarify the methodology used to calculate distributions. |
| 200122047(PDF, 42K) |
5/24/2001 |
| This is in reply to your letter of March 30, 2000, as modified by your letter of November 27, 2000. regarding the transfer of your assets to another voluntary employees' beneficiary association (VEBA) sponsored by your plan sponsor. |
| 200122046(PDF, 4.7K) |
6/1/2001 |
| This letter responds to a letter September 11, 2000, and subsequent correspondence, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200122045(PDF, 14K) |
6/1/2001 |
| This letter responds to your letter dated February 24, 2000, and subsequent correspondence, submitted on behalf of A and B, the grantors and trustees of Trust, requesting certain rulings under the Internal Revenue Code. |
| 200122044(PDF, 21K) |
6/1/2001 |
| This responds to your letter dated August 3, 2000, 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 ("Convention"). |
| 200122043(PDF, 6.2K) |
6/1/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200122042(PDF, 6.1K) |
6/1/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200122041(PDF, 36K) |
6/1/2001 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200122040(PDF, 5.8K) |
6/1/2001 |
| This letter responds to a letter dated August 18, 2000, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200122039(PDF, 6.1K) |
6/1/2001 |
| This responds to a letter submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200122038(PDF, 17K) |
6/1/2001 |
| This responds to your Authorized Representatives' letter dated August 30, 2000, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser, Shareholder A, and Shareholder B are requesting an extension to file a "§ 338(h)(10) election" under §§ 338(g) and 338(h)(10) of the Internal Revenue Code and § 1.338(h)(10)-1(d) of the Income Tax Regulations (the "Election"), with respect to Purchaser's acquisition of the Target stock on Date B, which is within Year F (the "Acquisition"). |
| 200122037(PDF, 13K) |
6/1/2001 |
| This letter responds to your request dated March 10, 2000, and subsequent submissions, submitted by your authorized legal representative on behalf of the Taxpayer. The request is for a revised schedule of ruling amounts under § 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund (the "Fund") under the jurisdiction of Commission A. |
| 200122036(PDF, 19K) |
6/1/2001 |
| This is in response to your May 11, 2000 letter requesting a ruling concerning the Federal gift tax treatment of the severance of a trust and proposed renunciation with respect to interests in the severed trust by Spouse. |
| 200122035(PDF, 9.9K) |
6/1/2001 |
| Requesting an extension of time pursuant to §301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as a partnership for federal tax purposes. |
| 200122034(PDF, 12K) |
6/1/2001 |
| This letter responds to your representative's letter, dated April 24, 2000, together with subsequent correspondence, submitted on behalf of Company, requesting a ruling that Company's subchapter S election will not terminate. |
| 200122033(PDF, 6.6K) |
6/1/2001 |
| This letter responds to your letter dated November 30, 2000, submitted on behalf of X, requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations for X to elect to be treated as an association taxable as a corporation for federal tax purposes. |
| 200122032(PDF, 5.8K) |
6/1/2001 |
| On Date A this office issued a private letter ruling (PLR # 9814007) ("Initial Ruling") concluding that the issuance of a qualified rate order (QRO) financing order by the State A public utility commission authorizing the collection of competitive transition charges did not result in gross income to Company and that Transition Bonds issued by the Trust were obligations of the Company. |
| 200122031(PDF, 11K) |
6/1/2001 |
| The request is for a revised schedule of ruling amounts under § 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund ("Fund") under the jurisdiction of Commission and has been filed because the Commission has adjusted the estimated date on which Plant will no longer be included in rate base. |
| 200122030(PDF, 11K) |
6/1/2001 |
| The request is for a revised schedule of ruling amounts under § 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund ("Fund") under the jurisdiction of Commission and has been filed because the Commission has adjusted the estimated date on which Plant will no longer be included in rate base. |
| 200122029(PDF, 11K) |
6/1/2001 |
| The request is for a revised schedule of ruling amounts under § 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund ("Fund") under the jurisdiction of Commission and has been filed because the Commission has adjusted the estimated date on which Plant will no longer be included in rate base. |
| 200122028(PDF, 8.4K) |
6/1/2001 |
| This responds to a letter dated November 20, 2000, together with subsequent correspondence, submitted on behalf of X, requesting a ruling that the rental income received in the course of its operations does not constitute passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200122027(PDF, 5.7K) |
6/1/2001 |
| This letter responds to a letter dated November 1, 2000, and subsequent correspondence, submitted by your authorized representative on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200122026(PDF, 15K) |
6/1/2001 |
| This is in reply to your letter dated November 8, 2000, in which you request a ruling under § 1.367(a)-3(c)(9) of the Income Tax Regulations, that, based on the representations in the letter, the exchange of shares by U.S. persons described below will qualify for an exception to the general rule of § 367(a)(1) of the Internal Revenue Code. |
| 200122025(PDF, 18K) |
6/1/2001 |
| This is in response to your November 14, 2000 letter and other communications requesting rulings on the application of the income, gift, and estate tax to a proposed transaction. |
| 200122024(PDF, 19K) |
6/1/2001 |
| Requesting rulings on behalf of Corporation concerning the application of § 2703 of the Internal Revenue Code to certain amendments to Corporation's Articles of Incorporation. |
| 200122023(PDF, 35K) |
6/1/2001 |
| Issues: (1) Whether Parent's bankruptcy converted Subsidiary's partnership items to nonpartnership items pursuant to Temporary Treasury Regulation § 301.6231(c)-7T(a), thereby terminating Subsidiary's status as tax matters partner (TMP) pursuant to Treas. Reg. § 301.6231(a)(7)-1(l)(1)(iv). (2) Whether the statute of limitations for assessment under § 6229 of the Internal Revenue Code remains open with respect to the partners. |
| 200122022(PDF, 108K) |
6/1/2001 |
| Issue: Whether Sub A, a subsidiary-member of a consolidated group, may deduct a loss purportedly realized on the sale of stock of one of its subsidiaries. |
| 200122021(PDF, 6.2K) |
6/1/2001 |
| This responds to a letter dated December 6, 2000, together with subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200122020(PDF, 11K) |
6/1/2001 |
| The request is for a revised schedule of ruling amounts under § 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund ("Fund") under the jurisdiction of Commission and has been filed because the Commission has adjusted the estimated date on which Plant will no longer be included in rate base. |
| 200122019(PDF, 18K) |
6/1/2001 |
| Issue: Does Rev. Proc. 2000-38 apply to amended returns filed before the issuance of the revenue procedure? |
| 200122018(PDF, 20K) |
6/1/2001 |
| Issues: (1) Whether the Service should deal directly with a split-off subsidiary in connection with an audit of the taxpayer, which was the common parent of an affiliated group of corporations that filed a consolidated income tax return for the years under audit. (2) Whether the requirements of § 7602(c) apply when a subsidiary ceases to be a member of a consolidated group. |
| 200122017(PDF, 6.2K) |
6/1/2001 |
| This responds to a letter dated September 5, 2000, together with subsequent correspondence, submitted on behalf of LLC, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200122016(PDF, 6.1K) |
6/1/2001 |
| This responds to a letter dated December 28, 2000, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200122015(PDF, 5.6K) |
6/1/2001 |
| This responds to your letter dated January 9, 2001, submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200122014(PDF, 5.8K) |
6/1/2001 |
| This responds to the letter dated November 20, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200122013(PDF, 12K) |
6/1/2001 |
| This refers to the letter dated October 24, 2000, which requests certain rulings regarding a regulated investment company ("RIC") that is eligible for "look-through" treatment under § 817(h)(4) of the Internal Revenue Code and § 1.817- 5(f) of the Income Tax Regulations in which shares of the RIC are acquired by a trustee of a pension or deferred compensation plan under the provisions of § 451(a), 415(m), and/or 457(f). |
| 200122012(PDF, 11K) |
6/1/2001 |
| This is in response to your letter of October 9, 2000, requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make a qualified family-owned business interests election under § 2057(b)(1)(B) of the Internal Revenue Code. |
| 200122011(PDF, 42K) |
6/1/2001 |
| Issues: (1) Whether a formula clause that allocates additional value to a charitable donee in the event the value of the transferred property is redetermined for federal transfer tax purposes will be respected for federal transfer tax purposes? (2) Whether the amount of a transfer may be reduced by the actuarial value of the estate taxes attributable to the potential § 2035(c) inclusion in the donors' gross estates? |
| 200122010(PDF, 6.9K) |
6/1/2001 |
| Requesting an extension of time pursuant to § 301.9100-3(a) of the Procedure and Administration Regulations to file an election under § 301.7701-3(c) to be disregarded as an entity separate from its owner for federal tax purposes. |
| 200122009(PDF, 14K) |
6/1/2001 |
| This is in response to your letter dated August 10, 2000, requesting a ruling on the federal tax consequences of certain specified amendments proposed to be made to the Plan. Employer is a municipality and an eligible employer within the meaning of § 457(e)(1)(A) of the Code. |
| 200122008(PDF, 53K) |
6/1/2001 |
| Applicability of Internal Revenue Code § 461(d) to timing of state franchise tax deductions on federal tax returns by an accrual method taxpayer. |
| 200122007(PDF, 39K) |
6/1/2001 |
| Issues: (1) Was CorpH's election to treat the purchase of the stock of CorpB, and its wholly owned subsidiary CorpC, as an asset acquisition, valid under Internal Revenue Code § 338. (2) Whether any gain realized by CorpB on the sale of CorpC stock is foreign base company income under I.R.C. § 954. (3) Whether CorpF's income should be increased under I.R.C. § 951, to reflect any additional subpart F income realized by CorpB on the sale of the CorpC stock. |
| 200122006(PDF, 13K) |
6/1/2001 |
| Issues: (1) What is the correct method of calculating the tax imposed by § 4261(b) of the Internal Revenue Code on domestic segments where one person charters an aInternal Revenue Coderaft and more than one person is a passenger on that aInternal Revenue Coderaft? (2) If X has calculated the tax on domestic segments incorrectly, is X entitled to relief from retroactive application of the tax under § 7805(b)(8). |
| 200122005(PDF, 107K) |
6/1/2001 |
| Issues: (1) Whether the cost sharing payments made by PR Co pursuant to (a) the Date 1 Cost Sharing Agreement (in Taxable Years 1 and 2) and (b) the cost sharing method of § 936(h)(5)(C)(i) (in Taxable Years 3 through 6) are "research and experimental expenditures" as defined for purposes of § 174. How should these cost sharing payments be characterized? (2) Whether or not PR Co was properly entitled to amortize its cost sharing payments, made to US Co under the Date 1 Cost Sharing Agreement and the cost sharing method of § 936(h)(5)(C)(i), under § 174 or some other provision, what are the tax consequences of ceasing to amortize such payments, as PR Co did in Taxable Year 7 when it elected to switch to the profit split method? Did suspending such amortization deductions constitute a change in method of accounting, notwithstanding the taxpayer's failure to seek consent to change accounting method? If suspending these amortization deductions constituted a change in accounting method, what is the effect of the change? |
| 200122004(PDF, 13K) |
6/1/2001 |
| Issue: Whether specially equipped greenhouses and a cold storage building used for growing and storing plants are a manufacturing facility within the meaning of §144(a)(12)(C) of the Internal Revenue Code? |
| 200122003(PDF, 6.1K) |
6/1/2001 |
| Requesting a ruling that X's S corporation status will be effective as of D1. |
| 200122002(PDF, 37K) |
6/1/2001 |
| Issues: (1) Whether the cost of tires and tubes purchased for new vehicles must be capitalized and recovered through depreciation, or is such cost currently deductible as a business expense? (2) If the cost of the tires and tubes must be capitalized, are the tires and tubes treated as separate assets for depreciation purposes and, if so, over what recovery period are they depreciated? (3) If the cost of tires and tubes must be capitalized, and tires and tubes are treated as separate assets for depreciation purposes, how is the cost of replacement tires and tubes recovered? (4) Whether a change from currently deducting the cost of tires and tubes to capitalizing and depreciating such cost is a change in method of accounting? |
| 200122001(PDF, 11K) |
6/1/2001 |
| Requesting several rulings under §§ 301, 305, 561, 562, and 857 of the Internal Revenue Code. |
| 200121082(PDF, 50K) |
5/23/2001 |
| This is in response to your letter dated December 6, 2000, in which you requested certain rulings with respect to a proposed transfer of all of the assets of B to C and D. |
| 200121081(PDF, 49K) |
5/22/2001 |
| This is in response to your letter dated December 6, 2000, in which you requested certain rulings with respect to a proposed transfer of all of the assets of B to C and D. |
| 200121080(PDF, 55K) |
5/21/2001 |
| This is in response to your letter dated December 6, 2000, in which you requested certain rulings with respect to a proposed transfer of all of the assets of B to C and D. |
| 200121079(PDF, 33K) |
5/20/2001 |
| This is in response to your request for a ruling, dated August 31, 1999, supplemented by letters dated October 29, 1999, April 21, 2000, and October 10, 2000, and facsimile dated February 21, 2001, submitted by your authorized representative concerning distributions from a plan described in § 401 (k) of the Internal Revenue Code . Your authorized representative submitted the following facts and representations in support of the requested ruling. |
| 200121078(PDF, 71K) |
5/19/2001 |
| This letter responds to X's request dated May 2, 2000 for a ruling that a private foundation's grants made to a foreign orphanage will comply with chapter 42 of the Internal Revenue Code. |
| 200121077(PDF, 32K) |
5/18/2001 |
| This is in reply to your ruling request of December 27, 1999, requesting approval of a set-aside of your income under the suitability test of § 4942(g)(2)(B)(i) of the Internal Revenue Code and § 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations. |
| 200121076(PDF, 31K) |
5/17/2001 |
| 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 July 31, 2000. |
| 200121075(PDF, 30K) |
5/16/2001 |
| 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 July 31, 2000. |
| 200121074(PDF, 40K) |
5/15/2001 |
| This letter constitutes defined benefit pension plan notice that with respect to the above-named minimum funding standard for we have granted a conditional waiver of the plan year ending July 31, 2000. |
| 200121073(PDF, 69K) |
5/14/2001 |
| This is in response to the letter submitted on your behalf by your authorized representative, as supplemented by correspondence and I in which you, through your authorized representative, request a series of letter rulings under § 401(a)(9) and 408(d)(3) of the Internal Revenue Code. The following facts and representations support your ruling request. |
| 200121072(PDF, 116K) |
5/13/2001 |
| This is in reply to your request for a ruling dated!, regarding certain federal income and excise tax consequences of the proposed transaction under § 72(e), 72(t), 401(a), 403(a), 403(b), 408(b), 3405.4972, 4973, and 4979 of the Internal Revenue Code of 1986, as amended. |
| 200121071(PDF, 43K) |
5/25/2001 |
| Lease stripping transactions. |
| 200121070(PDF, 21K) |
5/25/2001 |
| Issue: How should an individual who rents a portion of his dwelling unit to his employer and who uses the dwelling unit in performing services as an employee of that employer treat the expenses attributable to the rental of the dwelling unit? |
| 200121069(PDF, 16K) |
5/25/2001 |
| Request for a letter ruling supplementing our letter ruling dated August 1, 2000 (the "Prior Letter Ruling"). |
| 200121068(PDF, 6.3K) |
5/25/2001 |
| This letter responds to your letter dated August 4, 2000, and subsequent correspondence, written on behalf of X, a limited partnership, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121067(PDF, 6.3K) |
5/25/2001 |
| This letter responds to your letter dated August 4, 2000, and subsequent correspondence, written on behalf of X, a limited partnership, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121066(PDF, 6.4K) |
5/25/2001 |
| This letter responds to your letter dated August 4, 2000, and subsequent correspondence, written on behalf of X, a limited partnership, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121065(PDF, 6.3K) |
5/25/2001 |
| This letter responds to your letter dated August 4, 2000, and subsequent correspondence, written on behalf of X, a limited partnership, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121064(PDF, 6.3K) |
5/25/2001 |
| This letter responds to your letter dated August 4, 2000, and subsequent correspondence, written on behalf of X, a limited partnership, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121063(PDF, 6.3K) |
5/25/2001 |
| This letter responds to your letter dated August 4, 2000, and subsequent correspondence, written on behalf of X, a limited partnership, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121062(PDF, 6.4K) |
5/25/2001 |
| This letter responds to your letter dated August 4, 2000, and subsequent correspondence, written on behalf of X, a limited partnership, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121061(PDF, 16K) |
5/25/2001 |
| This is in reply to a letter dated November 8, 2000, in which rulings were requested as to the federal income tax consequences of a proposed transaction. Additional information was submitted in a letter dated December 29, 2000. |
| 200121060(PDF, 6.3K) |
5/25/2001 |
| This letter responds to your letter dated August 4, 2000, and subsequent correspondence, written on behalf of X, a limited partnership, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121059(PDF, 6.4K) |
5/25/2001 |
| X is requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121058(PDF, 6.3K) |
5/25/2001 |
| This letter responds to your letter dated August 4, 2000, and subsequent correspondence, written on behalf of X, a limited partnership, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200121057(PDF, 4.7K) |
5/25/2001 |
| This responds to your letter dated October 30, 2000, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200121056(PDF, 6.2K) |
5/25/2001 |
| This letter responds to your letter dated December 6, 2000, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200121055(PDF, 8.1K) |
5/25/2001 |
| This letter responds to your letter dated December 19, 2000, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200121054(PDF, 14K) |
5/25/2001 |
| This letter responds to a letter dated December 19, 2000, requesting rulings about the federal income tax consequences of a proposed transaction. |
| 200121053(PDF, 5.2K) |
5/25/2001 |
| Requesting that X be granted an extension of time to file an election under § 301.7701-3(c) of the Procedure and Administration Regulations to be treated as a corporation for its taxable year beginning D1. |
| 200121052(PDF, 6.0K) |
5/25/2001 |
| This responds to your letter dated October 20, 2000, and subsequent correspondence, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200121051(PDF, 4.7K) |
5/25/2001 |
| This letter responds to a letter dated June 5, 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. |
| 200121050(PDF, 5.4K) |
5/25/2001 |
| This is in reply to a letter dated August 31, 2000, submitted by X's authorized representative on behalf of X, requesting that X be given an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200121049(PDF, 8.3K) |
5/25/2001 |
| Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement required under § 1.1503-2(g)(2)(i) with respect to the Tax Years Ended X and Y, and to file the annual certification required under § 1.1503-2(g)(2)(vi) with respect to the Tax Year Ended X. |
| 200121048(PDF, 7.7K) |
5/25/2001 |
| This letter responds to a letter, dated August 22, 2000, and subsequent correspondence, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation status will be effective as of the taxable year beginning D3. |
| 200121047(PDF, 16K) |
5/25/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the PLR-122451-00. |
| 200121046(PDF, 25K) |
5/25/2001 |
| This letter responds to the request of Taxpayer, dated March 10, 2000, for a revised schedule of ruling amounts in accordance with § 1.468A-3(i) of the Income Tax Regulations. |
| 200121045(PDF, 25K) |
5/25/2001 |
| This letter responds to the request of Taxpayer, dated March 10, 2000, for a revised schedule of ruling amounts in accordance with § 1.468A-3(i) of the Income Tax Regulations. |
| 200121044(PDF, 15K) |
5/25/2001 |
| This is in response to your letter dated October 31, 2000, for rulings concerning the federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated January 3, 2001, January 4, 2001 and February 8, 2001. |
| 200121043(PDF, 17K) |
5/25/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200121042(PDF, 14K) |
5/25/2001 |
| This is in response to your letter dated October 31, 2000, for rulings concerning the federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated January 3, 2001, January 4, 2001 and February 8, 2001. |
| 200121041(PDF, 14K) |
5/25/2001 |
| A Parent is requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations for Parent to file an election. |
| 200121040(PDF, 9.1K) |
5/25/2001 |
| This is in response to letters of October 18, 2000, December 19, 2000, January 4, 2001 and February 7, 2001 requesting consent to Taxpayer's revocation of its election under § 831(b) to be taxed only on its investment income effective for the calendar 2000 tax year. |
| 200121039(PDF, 17K) |
5/25/2001 |
| 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. |
| 200121038(PDF, 6.0K) |
5/25/2001 |
| This responds to your letter dated October 20, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200121037(PDF, 6.7K) |
5/25/2001 |
| This letter responds to a letter dated October 16, 2000, and subsequent correspondence, submitted by your authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200121036(PDF, 6.2K) |
5/25/2001 |
| This letter responds to the ruling request dated November 1, 2000, which you submitted on behalf of X, and which requests relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200121035(PDF, 10K) |
5/25/2001 |
| This is in response to your letter dated October 20, 2000, requesting a ruling on behalf of A under § 877(c) of the Internal Revenue Code of 1986 (the "Code") that A's 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. |
| 200121034(PDF, 37K) |
5/25/2001 |
| Issue: Whether Company Z should be treated as a "person other than the taxpayer" for purposes of the advance notification requirements of Internal Revenue Code § 7602(c)(1). |
| 200121033(PDF, 11K) |
5/25/2001 |
| This responds to your letter dated December 27, 2000, submitted on behalf of X requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200121032(PDF, 5.8K) |
5/25/2001 |
| This letter responds to a letter dated October 13, 2000, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200121031(PDF, 18K) |
5/25/2001 |
| This responds to your undated letter received October 2, 2000, requesting a ruling on Taxpayer's behalf. |
| 200121030(PDF, 20K) |
5/25/2001 |
| This letter responds to your request dated, and subsequent submissions, submitted on behalf of Taxpayer. The request is for a revised schedule of ruling amounts under the review provisions of § 1.468A-3(i) of the Income Tax Regulations for Taxpayer. |
| 200121029(PDF, 11K) |
5/25/2001 |
| The request is for a revised schedule of ruling amounts under § 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund ("Fund") under the jurisdiction of Commission and has been filed because the Commission has adjusted the estimated date on which Plant will no longer be included in rate base. |
| 200121028(PDF, 64K) |
5/25/2001 |
| 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. |
| 200121027(PDF, 10K) |
5/25/2001 |
| This responds to a letter dated October 19, 2000, submitted on behalf of Fund. Fund requests that its election under § 855(a) of the Internal Revenue Code to treat dividends distributed after the close of a taxable year as having been paid during that tax year. |
| 200121026(PDF, 5.7K) |
5/25/2001 |
| This letter responds to a letter dated November 1, 2000, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200121025(PDF, 6.0K) |
5/25/2001 |
| This letter responds to a letter dated October 5, 2000, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200121024(PDF, 21K) |
5/25/2001 |
| You requested a ruling as to whether the proposed reformation of the income interests in Trust C and Trust D will result in the realization of gain or loss under § 1001 of the Internal Revenue Code. |
| 200121023(PDF, 21K) |
5/25/2001 |
| You requested a ruling as to whether the proposed reformation of the income interests in Trust C and Trust D will result in the realization of gain or loss under § 1001 of the Internal Revenue Code. |
| 200121022(PDF, 17K) |
5/25/2001 |
| Issue: Whether Taxpayer is required to take into account an adjustment under Internal Revenue Code § 481(a) in connection with a change to the inventory price index computation ["IPIC"] method made pursuant to Rev. Proc. 97-37, 1997-2 C.B. 455. |
| 200121021(PDF, 16K) |
5/25/2001 |
| Taxpayer is seeking this revised schedule of ruling amounts because three of the public utility commissions having regulatory authority over Taxpayer have changed the date on which the Plant will no longer be in rate base for ratemaking purposes. |
| 200121020(PDF, 16K) |
5/25/2001 |
| Taxpayer is seeking this revised schedule of ruling amounts because three of the public utility commissions having regulatory authority over Taxpayer have changed the date on which the Plant will no longer be in rate base for ratemaking purposes. |
| 200121019(PDF, 24K) |
5/25/2001 |
| Issue: The issue is whether, after Funds 1 through 33 consolidate into a number no fewer than V funds, the funds may deduct as "insurance" premiums under Internal Revenue Code § 162 and § 1.162-1(a) of the Income Tax Regulations amounts paid by the funds to Mutual, an assessable mutual insurance company in which the Funds are the only customers. |
| 200121018(PDF, 62K) |
5/25/2001 |
| In determining the foreign sales corporation (FSC) commission payable by Corp A to Corp A-FSC, whether the taxpayer may compute the overall profit percentage (OPP) under Temporary Treasury Regulation § 1.925(b)-1T(c)(2) of the marginal costing rules for a product by using the OPP for the product or product line grouping in which the product is included if, with respect to other products in the same product line, the taxpayer uses an OPP determined at a different, overlapping level of the product line hierarchy. |
| 200121017(PDF, 17K) |
5/25/2001 |
| Taxpayer is seeking this revised schedule of ruling amounts because three of the public utility commissions having regulatory authority over Taxpayer have changed the date on which the Plant will no longer be in rate base for ratemaking purposes. |
| 200121016(PDF, 50K) |
5/25/2001 |
| Issues: (1) Each Initial Feeder Fund will be deemed to own a proportionate share of each asset of its corresponding Master Trust and will be deemed to be entitled to the income of the Master Trust attributable to such share for purposes of determining whether the Initial Feeder Fund satisfies the requirements of §§ 851(b)(2), 851(b)(3), 852(b)(5), 853, and 854 of the Internal Revenue Code. (2) No Master Trust will be a publicly traded partnership taxed as a corporation under § 7704 of the Code. (3) No gain or loss will be recognized by any Master Trust or the Initial Feeder Funds upon a contribution of property by an Initial Feeder Fund solely in exchange for shares of beneficial interest in the Master Trust and the Master Trust's assumption of liabilities, if any. |
| 200121015(PDF, 12K) |
5/25/2001 |
| This is in response to your letter dated October 17, 2000, and prior correspondence, requesting several rulings concerning the application of § 2702 of the Internal Revenue Code. |
| 200121014(PDF, 17K) |
5/25/2001 |
| Taxpayer is seeking this revised schedule of ruling amounts because three of the public utility commissions having regulatory authority over Taxpayer have changed the date on which the Plant will no longer be in rate base for ratemaking purposes. |
| 200121013(PDF, 105K) |
7/6/2001 |
| Issue: Whether the taxpayer, the common parent of a consolidated group, may deduct a loss purportedly realized on the sale of stock of one of its subsidiaries. |
| 200121012(PDF, 28K) |
5/25/2001 |
| You have asked our advice as to whether the above referenced taxpayer's tax shelter-related liabilities could be compromised under the Commissioner's new authority to compromise based on the promotion of effective tax administration. |
| 200121011(PDF, 4.8K) |
5/25/2001 |
| This responds to your letter dated September 5, 2000, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200121010(PDF, 9.8K) |
5/25/2001 |
| This letter is in reply to your letter dated October 17, 2000, requesting rulings about the federal income tax consequences of a partially completed transaction. |
| 200121008(PDF, 37K) |
5/25/2001 |
| Issues: (1) Whether Taxpayer filed a timely claim for deficiency interest paid for 1988 in 1989 under § 6601 of the Internal Revenue Code. (2) Whether Taxpayer filed a timely claim for deficiency interest paid for 1989 in 1991 and 1992 under § 6601 of the Code. (3) Whether Taxpayer filed timely claims for overpayment interest under § 6611 of the Code for 1988 and 1989. |
| 200121007(PDF, 28K) |
5/25/2001 |
| Issue: Whether the tax return information of the buyers of a business may be disclosed, pursuant to Internal Revenue Code § 6103, to the petitioners in this litigation, one of whom was the seller of the business, in response to a five-part interrogatory propounded by the petitioners? |
| 200121006(PDF, 18K) |
5/25/2001 |
| Issue: Whether property, such as stuffed animals, novelty toys and jewelry ("prizes"), which T offers to customers in its mechanical skill crane devices and treats as inventory when computing its combined absorption ratio under the simplified resale method, is subject to § 263A of the Internal Revenue Code. |
| 200121005(PDF, 11K) |
5/25/2001 |
| This is in reply to a letter dated August 11, 2000 requesting a ruling on behalf of Fund. You have requested a ruling that Fund be granted an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an election under § 85. |
| 200121004(PDF, 17K) |
5/25/2001 |
| This letter responds to your request for rulings dated June 2, 2000, and subsequent correspondence, submitted on behalf of a group of mutual funds (referred to individually as Fund and collectively as Funds). Each Fund has requested rulings that the award of "points" under an awards program will be treated for federal income tax purposes as an adjustment of an investor's purchase price for its shares, and will result in an adjustment to its basis in those shares; and that the award of points and the subsequent redemption of points, will not result in the payment of preferential dividends by a Fund within the meaning of § 562(c) of the Internal Revenue Code. |
| 200121003(PDF, 11K) |
5/25/2001 |
| This letter is in reply to your letter dated February 22, 2000, and subsequent correspondence, requesting a ruling that the distribution fees of Fund A and Fund B (collectively referred to as Funds ) are deductible under § 162(a) of the Internal Revenue. |
| 200121002(PDF, 8.7K) |
5/25/2001 |
| This is in reply to a letter dated July 27, 2000, and subsequent correspondence, requesting a ruling on behalf of Trusts A-K (Trusts) and Funds A-GG (Funds). You request a ruling that certain payments made by a Lower Tier Fund (as described below) or the Adviser under certain expense arrangements will not result in the payment of preferential dividends within the meaning of § 562(c) of the Internal Revenue Code that may cause the Lower Tier Fund to fail to qualify as a regulated investment company (RIC) under subchapter M of Chapter 1 of the Code. |
| 200121001(PDF, 32K) |
5/25/2001 |
| Advisory opinion refund of third-party deposits upon rejections of offers in compromise. |
| 200120044(PDF, 34K) |
5/12/2001 |
| This is in reference to your letters of November 15, 2000, and January 30, 2001 requesting a ruling that grants made under the program described below will not constitute taxable expenditures within the meaning of § 4945(d)(3) and that amounts distributed to students will constitute scholarship grants within the meaning of § 117(a). This letter modifies the private letter ruling dated January 19,200l that you received. |
| 200120043(PDF, 54K) |
5/11/2001 |
| This is in response to your letter dated November 15, 2000, in which you requested certain rulings with respect to a proposed transfer of assets from B to C. |
| 200120042(PDF, 33K) |
5/10/2001 |
| This letter is in response to a request for a private letter ruling dated and supplemented by additional correspondence dated and submitted on your behalf by your authorized representative, regarding the federal income tax treatment of certain contributions to Plan X under § 414(h) (2) of the Internal Revenue Code. |
| 200120041(PDF, 51K) |
5/9/2001 |
| This is in response to your letter dated November 15, 2000, in which you requested certain rulings with respect to a proposed transfer of assets from B to C. |
| 200120040(PDF, 44K) |
5/8/2001 |
| This is in response to the letter, submitted by your authorized representative, in which you request relief under § 301.9100-3 of the Procedure and Administration Regulations. The following facts and representations support your ruling request. |
| 200120039(PDF, 22K) |
5/7/2001 |
| This letter constitutes notice that waivers of the IO percent tax under § 4971(f)(l) of the Internal Revenue Code have been granted for the above-named defined benefit plan for the last quarter of the plan year ending December 31, 1996, and for the first three quarters of the plan year ending December 31, 1997. |
| 200120038(PDF, 22K) |
5/6/2001 |
| This letter constitutes notice that waivers of the 10 percent tax under § 4971(f)(l) of the Internal Revenue Code have been granted for the above-named defined benefit plan, for the first, third, and fourth quarters of the plan year ending March 31, 1998. |
| 200120037(PDF, 21K) |
5/17/2001 |
| Issue: Whether rental income received by a taxpayer in situations 1 and 2 below is disqualified income for purposes of § 32(i) of the Internal Revenue Code. |
| 200120036(PDF, 46K) |
5/17/2001 |
| Issue: Whether rental income received by a taxpayer from the lease of a building owned by the taxpayer to the taxpayer's wholly owned C corporation is disqualified income for purposes of § 32(i) of the Internal Revenue Code. |
| 200120035(PDF, 24K) |
5/17/2001 |
| Issue: With respect to a frivolous refund claim based on a claim of entitlement to an invalid, nonexistent credit (such as for Black reparations), you ask can the Service, and if so by what procedures or remedies, refuse to post the credit to the account, reverse a frivolous credit posted to the account, stop FMS from processing a refund voucher (whether for a check or an electronic fund transfer, EFT), intercept a mailed check or EFT, recover the check from the hands of the taxpayer or the bank prior to final processing of the check, recover deposited Treasury check or EFT proceeds before or after the proceeds become available for withdrawal, or recover Treasury check proceeds withdrawn from the bank account by the taxpayer? |
| 200120034(PDF, 9.1K) |
5/17/2001 |
| This responds to a letter dated December 22, 2000, requesting that the Taxpayers be granted an extension of time to file an election under § 1092(b) of the Internal Revenue Code of 1986 and § 1.1092(b)-4T(f) of the Temporary Income Tax. |
| 200120033(PDF, 8.7K) |
5/17/2001 |
| This responds to a letter dated July 27, 2000, and subsequent correspondence, submitted on behalf of X, requesting a determination concerning the eligibility of X to treat Y its wholly owned subsidiary as a Qualified Subchapter S Subsidiary pursuant to § 1361(b)(3). |
| 200120032(PDF, 6.7K) |
5/17/2001 |
| This responds to the letter dated October 16, 2000, and subsequent correspondence, submitted on behalf of Partnership, requesting an extension of time pursuant to § 301.9100-3(a) of the Procedure and Administration Regulations to file an election under § 754 of the Internal Revenue Code. |
| 200120031(PDF, 4.6K) |
5/17/2001 |
| This responds to a letter dated October 5, 2000, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200120030(PDF, 21K) |
5/17/2001 |
| This letter responds to your August 18, 2000 request for rulings on certain federal income tax consequences. |
| 200120029(PDF, 6.8K) |
5/17/2001 |
| Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement described in § 1.1503-2(g)(2)(i). |
| 200120028(PDF, 6.9K) |
5/17/2001 |
| This replies to letters dated March 22, 2000, and December 6, 2000, in which Taxpayer 3 requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement required by § 1.1503-2(g)(2)(iv)B)(2)(iii) for the tax year ended on Date B. |
| 200120027(PDF, 6.3K) |
5/17/2001 |
| This responds to a letter dated October 10, 2000, together with subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200120026(PDF, 25K) |
5/17/2001 |
| This letter responds to the request of Taxpayer, dated March 3, 2000, for a revised schedule of ruling amounts in accordance with § 1.468A-3(i) of the Income Tax Regulations. |
| 200120025(PDF, 25K) |
5/17/2001 |
| This letter responds to the request of Taxpayer, dated March 3, 2000, for a revised schedule of ruling amounts in accordance with § 1.468A-3(i) of the Income Tax Regulations. |
| 200120024(PDF, 11K) |
5/17/2001 |
| This is in reply to a letter dated May 31, 2000, submitted on behalf of the Employer. The Employer has requested a ruling on the federal income tax consequences under § 401(k) and 451 of the Internal Revenue Code with respect to the proposed transaction. |
| 200120023(PDF, 6.7K) |
5/17/2001 |
| This letter responds to your December 1, 2000 request for a private letter ruling, submitted on behalf of LP, requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200120022(PDF, 14K) |
5/17/2001 |
| This is in response to your letter dated September 28, 2000, on behalf of the Fund requesting a ruling on the proper treatment of certain employee contributions made to retirement programs operated by the Board under § 414(h)(2) and 457 of the Internal Revenue Code. This ruling only addresses the deferred compensation program intended to meet the requirements of § 457(b) of the Code. |
| 200120021(PDF, 8.9K) |
5/17/2001 |
| Requesting a ruling on whether the trustee's and Trust Protector's power under Article II, § 5, of the Trust Agreement will cause the Trust property to be includible in Settlor's gross estate. |
| 200120020(PDF, 11K) |
5/17/2001 |
| This is in reply to your letter dated January 31, 2000, and subsequent correspondence, submitted on behalf of P1, requesting certain rulings regarding P1's proposal to issue unsecured debt to refinance certain outstanding debt obligations. |
| 200120019(PDF, 11K) |
5/17/2001 |
| This responds to a letter dated November 7, 2001, on behalf of the above-referenced taxpayer, requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make a reverse qualified terminable interest property. |
| 200120018(PDF, 5.7K) |
5/17/2001 |
| This letter responds to a letter dated October 23, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200120017(PDF, 4.4K) |
5/17/2001 |
| 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. |
| 200120016(PDF, 20K) |
5/17/2001 |
| This letter responds to a letter dated January 27, 2000, and subsequent correspondence, written on behalf of Trust, requesting the following rulings regarding a proposed division of Trust into two separate trusts, Trust A and Trust B. |
| 200120015(PDF, 10K) |
5/17/2001 |
| This letter responds to your August 7, 2000 request for a supplement to our prior letter ruling dated May 8, 2000 (the "Prior Letter Ruling"). The Prior Letter Ruling addressed certain federal income tax consequences of a series of transactions that led ultimately to the distribution of Controlled stock by Distributing pro rata to its shareholders (the "Transaction"). |
| 200120014(PDF, 19K) |
5/17/2001 |
| Ruling about whether certain of the Company's facilities will qualify as facilities for "the local furnishing of electric energy" within the meaning of § 142 of the Internal Revenue Code of 1986. |
| 200120013(PDF, 5.7K) |
5/17/2001 |
| This responds to the letter dated December 18, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200120012(PDF, 6.2K) |
5/17/2001 |
| This letter responds to the ruling request dated January 17, 2001, which was submitted by your representative on behalf of X, and which requests relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200120011(PDF, 67K) |
5/17/2001 |
| Issues: (1) Whether the transactions described below lack economic substance. (2) Alternatively, whether the transactions described below should be recharacterized as a financing. |
| 200120010(PDF, 7.8K) |
5/17/2001 |
| This letter responds to a letter dated U, requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations for Taxpayer to file a copy of a Form 3115, Application for Change in Accounting Method, with the Internal Revenue Service (IRS) national office. |
| 200120009(PDF, 24K) |
5/17/2001 |
| Issues: S Whether an offer in compromise regarding a joint liability that was entered into as a result of a mutual mistake of material fact will prevent a taxpayer from being relieved of the joint liability at a later date? Whether a mutual mistake of material fact has occurred when the spouse does not raise the issue of relief from liability under § 6013(e) or 6015 prior to the acceptance of an offer in compromise? |
| 200120008(PDF, 7.8K) |
5/17/2001 |
| This letter responds to a letter dated u, requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations for Taxpayer to file a copy of a Form 3115, Application for Change in Accounting Method, with the Internal Revenue Service (IRS) national office. |
| 200120007(PDF, 27K) |
5/17/2001 |
| This is in response to your letter dated Date 1, and additional submissions on behalf of Trust 1, H, W (H's spouse), and Trust 5 (referred to collectively as "Taxpayers"), requesting rulings concerning the income and generation-skipping transfer tax consequences of proposed transfers of policies insuring the lives of H and W. |
| 200120006(PDF, 64K) |
5/17/2001 |
| Unissued state licenses are not property under the mail fraud statute. |
| 200120005(PDF, 9.2K) |
5/17/2001 |
| Issue: Is Taxpayer liable for the excise tax imposed under § 48.4081-4(b)(3) of the Manufacturers and Retailers Excise Tax Regulations on its sale of butane under the cInternal Revenue Codeumstances described below? |
| 200120004(PDF, 19K) |
5/17/2001 |
| This Field Service Advice responds to your memorandum on Date A. Field Service Advice is not binding on Examination or Appeals and is not a final case determination. |
| 200120003(PDF, 17K) |
5/17/2001 |
| Request for rulings concerning the tax status of the Foundation and the estate tax consequences of the proposed transfer of the Land Estate from the Trust to the Foundation under § 501(c)(3) and § 2055(a)(2) of the Internal Revenue Code. |
| 200120002(PDF, 17K) |
5/17/2001 |
| Request for rulings concerning the tax status of the Foundation and the estate tax consequences of the proposed transfer of the Land Estate from the Trust to the Foundation under § 501(c)(3) and § 2055(a)(2) of the Internal Revenue Code. |
| 200120001(PDF, 65K) |
5/17/2001 |
| Issues: (1) Are automobile dealers' transfers of customer notes to Taxpayer (a) sales of such customer notes or (b) pledges of such customer notes as security for loans made by Taxpayer to the dealers? And if the transfers described in (1) were sales: (2) What is Taxpayer's basis in the customer notes that it has purchased? (3) Did the customer notes purchased by Taxpayer have market discount within the meaning of § 1278(a)(2) of the Internal Revenue Code? (4) Under what cInternal Revenue Codeumstances would Taxpayer be entitled to a deduction for wholly or partially worthless debt under § 166 for a customer note that it has purchased? |
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