| 200149046(PDF, 29K) |
4/12/2002 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ending December 31, 2000. We have also modified our ruling letter dated May 5, 2000. |
| 200149045(PDF, 82K) |
4/12/2002 |
| We have considered your ruling request dated September 25, 2000 pertaining to the consequences under § 170,502(c)(3), 509. and 511-514 of the Internal Revenue Code of a 509(a)(3) supporting organization's creation of a donor-advised charitable gift fund. |
| 200149044(PDF, 35K) |
4/12/2002 |
| This letter responds to the request of counsel for B, C and D, dated June 1, 2000, for a ruling regarding a proposed reorganization of two charities, B and C, along with the creation of a new charity, D. |
| 200149043(PDF, 58K) |
4/12/2002 |
| This is in response to a letter dated March 9, 2001, from X's authorized representatives, who requested certain modifications to rulings issued to 21 in a previous private letter ruling (hereinafter the "Previous PLR") dated June 28, 1999 (PLR 1999-38-041). |
| 200149042(PDF, 48K) |
4/12/2002 |
| This is in response to a letter dated November 7, 2000, as supplemented by correspondence dated June 28, 2001, and July 19, 2001, submitted by your authorized representative, in which you request relief under § 301.9100-3 of the Procedure and Administration Regulations (the "regulations"). The following facts and representations were submitted in connection with your request. |
| 200149041(PDF, 21K) |
4/12/2002 |
| 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 February 28, 2001. |
| 200149040(PDF, 26K) |
4/12/2002 |
| We have considered ruling request of Foundation dated April 17, 2001, and supplemental information letter dated July 2, 2001 in which Foundation requested a ruling that contributions by Foundation and the life tenant of a proportional share of the total cost of proposed improvements to Foundation property ("Property") will not constitute acts of self-dealing under § 4941(d) of the Internal Revenue Code or result in the imposition of taxes under § 4941(a) of the Code. |
| 200149039(PDF, 37K) |
4/12/2002 |
| This is in reply to your ruling request of December 5, 2000, 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, beginning in your tax year ending on December 31, 2000. |
| 200149038(PDF, 63K) |
4/12/2002 |
| This is in response to a request for a private letter ruling submitted on behalf of Entity A dated October 4, 2000 and supplemented by additional correspondence dated May 4, 2001 and June 28, 2001. The ruling request concerns whether Plan X qualifies as a church plan under § 414(e) of the Internal Revenue Code. |
| 200149037(PDF, 45K) |
4/12/2002 |
| This is in response to the letter submitted by your authorized representative, as supplemented by correspondence in which you request relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200149036(PDF, 49K) |
4/12/2002 |
| This letter is in response to a request, submitted on your behalf by your authorized representative. You have requested rulings regarding the federal income tax treatment of certain contributions to Plan X and Plan Y under § 402 and 404 of the Internal Revenue Code. |
| 200149035(PDF, 41K) |
4/12/2002 |
| We have considered M's ruling request dated January 19, 2001. M has requested a ruling as to the effects of a merger of a taxable subsidiary, O into M, O's tax exempt parent. |
| 200149034(PDF, 16K) |
12/7/2001 |
| Issue: Whether an authorized agent under § 3504 of the Internal Revenue Code ("Agent") filing returns reporting employment taxes on wages paid to choreworkers should use the Agent's Employer Identification Number (EIN) on Forms 941, 940, W-2 and W-3. |
| 200149033(PDF, 20K) |
12/7/2001 |
| Internal Revenue Code § 2057 Federal Estate Tax Lien on Personal Property This memorandum responds to your e-mail request for advice, pertaining to the special estate tax election under I.R.C. § 2057. |
| 200149032(PDF, 21K) |
12/7/2001 |
| Issues: (1) Whether a substitute for return (SFR) relating to an income tax liability is a return under § 6020(b)? (2) Whether § 6501(b)(3) prohibits the Service from making an assessment after the taxpayer defaults on a statutory notice of deficiency related to a 6020(b) return? (3) When a taxpayer files a return showing a lower tax liability than the liability assessed from a SFR, whether the Service may reduce the SFR assessment to it equal to the amount of tax shown on taxpayer's return or abate the entire SFR assessment and reassess the lower liability from taxpayer's return? Whether § 6501(b)(3) affects the collection statute under § 6502? (5) Given that the Service has already assessed the taxpayer's liability under the deficiency procedures and that the Service does not abate such an assessment and make a new assessment when it reduces the tax liability pursuant to a late-filed return, is IRM Procedural Update 00230 correct in requiring that the collection statute expiration date ("CSED") be adjusted so that the 10-year collection period runs from the adjustment input date of the taxpayer's late filed return? |
| 200149031(PDF, 29K) |
12/7/2001 |
| This responds to your letter dated April 20, 2001, in which you requested a ruling and closing agreement under Rev. Proc. 92-39, 1992-1 C.B. 860, that premiums received by A 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 Treaty Between Ireland and the United States. |
| 200149030(PDF, 13K) |
12/7/2001 |
| This is in response to your authorized representative's letter and submissions of November 9, 2000, in which he requested on your behalf certain rulings regarding the proper federal income tax treatment, including any reporting and/or withholding obligations, for certain tuition reduction and reimbursement benefits provided to employees of various educational functions, activities and components of X and Y under the B tuition reduction plan. |
| 200149029(PDF, 5.8K) |
12/7/2001 |
| This letter responds to a letter dated May 30, 2001, requesting a ruling on behalf of X under § 1362(b)(5) of the Internal Revenue Code. |
| 200149028(PDF, 22K) |
12/7/2001 |
| This Chief Counsel Advice responds to your memorandum dated June 8, 2001. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200149027(PDF, 9.8K) |
12/7/2001 |
| This responds to your representative's letter dated June 5, 2001, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200149026(PDF, 5.5K) |
12/7/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200149025(PDF, 18K) |
12/7/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective January 3, 2001. |
| 200149024(PDF, 18K) |
12/7/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion concerning a reconsideration request from the following business as to whether it continues to be an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200149023(PDF, 13K) |
12/7/2001 |
| This Chief Counsel Advice responds to your memorandum dated April 11, 2001. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200149022(PDF, 18K) |
12/7/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased being an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective January 22, 1999. |
| 200149021(PDF, 7.8K) |
12/7/2001 |
| Parent requests an extension of time under Treasury Regulation § 301.9100-3 to file the statement of election and agreement provided under § 1.1503-2(g)(2) with respect to the losses of Subsidiary incurred in tax years ended on Dates 1, 2 and 3. |
| 200149020(PDF, 6.4K) |
12/7/2001 |
| For what are represented to be valid business reasons it is proposed that all of the outstanding shares of Controlled stock held by the ("Redeeming Shareholders") be redeemed. |
| 200149019(PDF, 80K) |
12/7/2001 |
| Issues: (1) Whether U.S. Corporation 1's contribution to U.S. Partnership of the right to receive licensing fees in exchange for an interest in the partnership was a contribution of property subject to § 721 and 704(c). (2) Whether U.S. Corporation 1's contribution to U.S. Partnership of the right to receive licensing fees was an impermissible assignment of income. (3) Whether § 482 permits reallocation to U.S. Corporation 1 of licensing-fee income that it contributed to U.S. Partnership. (4) Whether the licensing transactions at issue generated foreign trading gross receipts (FTGR) under § 924. (5) Whether U.S. Partnership and Hybrid Entity may file amended U.S. Partnership Returns of Income (Forms 1065) and/or Requests for Administrative Adjustment, (Forms 8082) to reflect special allocations of FSC-commission deductions. |
| 200149018(PDF, 6.0K) |
12/7/2001 |
| This letter responds to a letter dated October 12, 2000, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200149017(PDF, 24K) |
12/7/2001 |
| This Chief Counsel Advice responds to your memorandum dated February 7, 2001. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200149016(PDF, 12K) |
12/7/2001 |
| This is in response to a letter dated February 8, 2001, and subsequent correspondence, requesting a ruling under § 2522 of the Internal Revenue Code regarding two proposed transfers to Trust. |
| 200149015(PDF, 20K) |
12/7/2001 |
| Issues: (1) The proposed disclaimer by Child will constitute a qualified disclaimer within the meaning of § 2518 of the Code. (2) That the amount passing to Foundation by reason of Child's proposed disclaimer will be treated as passing from Decedent to Foundation for purposes of § 2055(a) of the Code and thus will qualify as a federal estate tax charitable deduction for Estate. |
| 200149014(PDF, 24K) |
12/7/2001 |
| Application of Internal Revenue Code § 6213(b)(3) This Chief Counsel Advice responds to your memorandum dated May 31, 2001. In accordance with I.R.C. § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200149013(PDF, 17K) |
12/7/2001 |
| Issues: (1) That the Trust established in the reorganization plan qualifies as a qualified settlement fund within the meaning of § 468B of the Internal Revenue Code and the regulations thereunder. The Trust will be treated as a separate tax entity; (2) That the Trust will be subject to tax on its modified gross income as defined in § 1.468B-2(a) of the Income Tax Regulations, at a rate equal to the maximum rate in effect for that taxable year under § 1(e) of the Internal Revenue Code; (3) That the transfer of Company's stock into the Trust and the transfer of cash and other assets into the Trust on behalf of Company to resolve the liability that the Trust was created to assume, will not constitute gross income to the Trust; and (4) That Company will be entitled to deduct transfers made to the Trust, in the year of each payment, to the extent that they do not represent settlements from insurance claims that are excludable from gross income. |
| 200149012(PDF, 2.9K) |
12/7/2001 |
| Issue: Whether certain communications services are exempt from the excise tax imposed by § 4251 of the Internal Revenue Code by reason of § 4253(f). |
| 200149011(PDF, 21K) |
12/7/2001 |
| Issue: Whether the Service has an interest, pursuant to its tax lien or by levy, in money in a bank account deposited by the clerk of a state court pursuant to a state court action. If the Service does have an interest, how should it assert its interest. |
| 200149010(PDF, 17K) |
12/7/2001 |
| May an executor of a deceased spouse's estate elect the application of Internal Revenue Code § 6015 (b) and (c) (pertaining to relief from joint and several liability) on behalf of a deceased individual? |
| 200149009(PDF, 24K) |
12/7/2001 |
| Issues: (1) Where a consolidated group includes two organizations described in Internal Revenue Code § 833 (Internal Revenue Code § 833 organizations) and a non-insurance subgroup, how should the taxable income limitation on the I.R.C. § 833(b) deduction be computed? (2) Where a consolidated group includes two I.R.C. § 833 organizations, should the taxable income limitation on the I.R.C. § 833(b) deduction be computed separately for each organization, or should all such organizations be combined for computation purposes? (3) If an I.R.C. § 833 organization joins a consolidated group on Date 2, and ratably allocates its items between the separate and consolidated periods, how should the I.R.C. § 833(b) deduction be computed? (4) If an I.R.C. § 833 organization joins a consolidated group on Date 2, and its short taxable year ending Date 1 resulted in a loss which created a SRLY NOL deduction for that organization in the consolidated return for the year ending Date 3, how should the SRLY limitations be applied in computing the I.R.C. § 833(b) deduction? |
| 200149008(PDF, 25K) |
12/7/2001 |
| By way of memorandum dated June 29, 2001, you asked for our review of the debtor's proposed Chapter 11 plan and disclosure statement involving an Internal Revenue Code § 368 reorganization. We forwarded these documents to the office of Associate Chief Counsel (Corporate), and the following reflects their views. |
| 200149007(PDF, 133K) |
12/7/2001 |
| Deductibility under Internal Revenue Code § 170 of a contribution of a portion of taxpayers' interests in a cooperative apartment to a public charity. |
| 200149006(PDF, 33K) |
12/7/2001 |
| This responds to your memorandum dated June 26, 2001, in which you asked for our comments on the debtor's proposed Chapter 11 plan and disclosure statement with respect to the liquidating trust. |
| 200149005(PDF, 6.2K) |
12/7/2001 |
| We received a letter from your authorized representative requesting permission for Taxpayer to revoke its election to compute its credit for increasing research activities (research credit) under the alternative incremental research credit rules of § 41(c)(4). This letter is in response to that request. |
| 200149004(PDF, 8.0K) |
12/7/2001 |
| Requesting permission for Taxpayer to revoke its election to compute its credit for increasing research activities (research credit) under the alternative incremental research credit rules of § 41(c)(4). |
| 200149003(PDF, 20K) |
12/7/2001 |
| Issue: Whether Insurance Subsidiary, which provided coverage only to its sibling operating subsidiaries, is an insurance company for federal income tax purposes subject to the provisions of Part II of subchapter L of the Internal Revenue Code? |
| 200149002(PDF, 45K) |
12/7/2001 |
| Issue: Whether the interest expense incurred by a commission foreign sales corporation ("FSC") that determines its income under the § 925(a)(2) combined taxable income method is 100% allocable to income effectively connected with the conduct of a trade or business within the United States and, thus, 100% deductible by the FSC. |
| 200149001(PDF, 11K) |
12/7/2001 |
| Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 |
| 200148085(PDF, 36K) |
4/12/2002 |
| This is in reply to a letter dated August 9, 2001, from your authorized representative, and previous correspondence, wherein you requested certain rulings concerning the federal tax consequences of the transactions described below. |
| 200148084(PDF, 41K) |
4/12/2002 |
| This is in reply to your letter dated May 11, 2000, requesting rulings on the proper application of § 72 of the Internal Revenue Code . Your request was originally sent to Employee Plans Technical Group (1) That office forwarded your request to our office for response. You modified your original request in letters dated July 27, 2001 and September 4, 2001. |
| 200148083(PDF, 61K) |
4/12/2002 |
| This is in response to your letter dated July 19, 2001, in which you requested certain rulings with respect to a proposed transfer of all of the assets of B to C. |
| 200148082(PDF, 62K) |
4/12/2002 |
| This is in response to your letter dated July 19, 2001, in which you requested certain rulings with respect to a proposed transfer of all of the assets of B to C. |
| 200148081(PDF, 30K) |
4/12/2002 |
| This is in response to a letter ruling request dated December 28, 2000, as supplemented by correspondence dated August 20, 2001, submitted on your behalf by your authorized representative. In your letter, you request a ruling regarding the effect of the establishment of Plan B on the qualified status of Plan A. You provided the following facts and representations in connection with your request. |
| 200148080(PDF, 47K) |
4/12/2002 |
| This is in response to L's letter requesting a ruling regarding a proposed exchange of assets in satisfaction of a bequest to L. L maintains that the transaction will not result in the loss of L's tax-exempt status under § 501 (c)(3) of the Internal Revenue Code or constitute "self-dealing" under § 4941. |
| 200148079(PDF, 22K) |
4/12/2002 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ending December 31, 2000. |
| 200148078(PDF, 70K) |
4/12/2002 |
| We have considered M's ruling request dated February 28, 2001. M has requested a ruling as to the tax implications of conducting certain activities through a controlled for-profit subsidiary. |
| 200148077(PDF, 53K) |
4/12/2002 |
| This is in response to your request for a ruling submitted by your authorized representative, dated May 5, 2000. concerning distributions from an arrangement described in § 403(b) of the Internal Revenue Code. A letter dated July 17, 2000, supplemented the request. |
| 200148076(PDF, 26K) |
4/12/2002 |
| 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 August 31, 2000. |
| 200148075(PDF, 43K) |
4/12/2002 |
| This is in response to your request for a private letter ruling, dated xxxxx, as supplemented by a letter dated xxxxx, concerning the applicability of § 415(m) of the Internal Revenue Code to an excess benefit plan and the tax consequences of certain related transactions. You submitted the following facts and representations in support of your request. |
| 200148074(PDF, 55K) |
4/12/2002 |
| This is in response to letters dated May 23 and July 31, 2001, and previous correspondence submitted by your authorized representatives on behalf of M and its title holding corporations, requesting a ruling on the proper treatment under § 512 of the Internal Revenue Code of certain payments M and its title holding corporations intend to receive in connection with the provision of telecommunications services, telecommunications related services, and utility services. |
| 200148073(PDF, 44K) |
4/12/2002 |
| 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. |
| 200148072(PDF, 54K) |
4/12/2002 |
| This is in response to your letter dated May 17, 2001, and June 11, 2001, requesting rulings under § 4941 of the Internal Revenue Code on behalf of the interests identified hereafter. |
| 200148071(PDF, 50K) |
4/12/2002 |
| This is in response to your letter dated May 17, 2001, requesting rulings under § 4941 of the Internal Revenue Code on behalf of the interests identified hereafter. |
| 200148070(PDF, 26K) |
4/12/2002 |
| This is in reference to your letter of June 29, 2001, requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200148069(PDF, 49K) |
4/12/2002 |
| This is in response to a letter dated January 10, 2001, submitted by MS authorized representatives, who request certain rulings concerning the federal tax consequences of the transaction described below. |
| 200148068(PDF, 25K) |
4/12/2002 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan, conditional waivers of the 100 Percent excise tax under § 4971(c) of the Internal Revenue Code have been granted for the tax years ended June 30, 1997-1999. |
| 200148067(PDF, 19K) |
4/12/2002 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ending December 31, 2000. |
| 200148066(PDF, 38K) |
4/12/2002 |
| You requested rulings on behalf of C and F involving the federal income tax consequences of the pledge by C to F of an option to purchase C's common stock (Option) and the subsequent transfer to and exercise of the Option by an unrelated § 501(c)(3) organization under § 170, 511, 4940, and 4941 of the internal Revenue Code of 1986 (Code). |
| 200148065(PDF, 53K) |
4/12/2002 |
| This letter constitutes notice that, with respect to the above-named money purchase pension plan, we have granted a conditional waiver of the minimum funding standard for the plan year ending June 30, 2000. You previously withdrew your request for an application for approval of a plan amendment that would have retroactively reduced benefits for the plan year ending June 30, 2000. |
| 200148064(PDF, 25K) |
4/12/2002 |
| This is in reference to your letter of June 25, 2001, requesting a ruling that expenditures pursuant to the program described will not constitute taxable expenditures within the meaning of § 4945(d) of the Internal Revenue Code. |
| 200148063(PDF, 39K) |
4/12/2002 |
| This is in reference to your letter of June 21, 2001, requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200148062(PDF, 41K) |
4/12/2002 |
| This is in reference to your letter of June 21, 2001, requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200148061(PDF, 20K) |
4/12/2002 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ending December 31, 2000. |
| 200148060(PDF, 40K) |
4/12/2002 |
| This is in reference to your letter of June 21, 2001, requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200148059(PDF, 33K) |
4/12/2002 |
| This is in reference to your letter of June 21, 2001, requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200148058(PDF, 38K) |
4/12/2002 |
| This is in reference to your letter of June 21, 2001, requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200148057(PDF, 95K) |
4/12/2002 |
| This is in response to a letter dated September 29, 2000, from M's authorized representative, who has requested certain rulings on M's behalf. |
| 200148056(PDF, 35K) |
4/12/2002 |
| This in reference to your letter dated May 2, 2001, requesting advance approval of your amended grant procedures. |
| 200148055(PDF, 37K) |
4/12/2002 |
| This is in response to a letter dated October 13, 2000, as supplemented by additional correspondence dated February 22, 2001, in which your authorized representative requested a ruling on your behalf under § 414(e) of the Internal Revenue Code. You submitted the following facts and representations in support of your request. |
| 200148054(PDF, 66K) |
4/12/2002 |
| This is in response to a request for a private letter ruling, dated February 15, 1998, as supplemented by letters dated November 2,1998, February 19, 2001, and June 4, 2001, which your authorized representative submitted on your behalf concerning certain proposed transactions. Your authorized representative submitted the following facts and representations in support of the ruling request. |
| 200148053(PDF, 103K) |
11/30/2001 |
| In its disposition of a somewhat novel issue, the United States Court of Appeals for the Fifth CInternal Revenue Codeuit decided that a Chapter 7 trustee did not "commence distribution" of assets until the bankruptcy court approved the trustee's final report and accounting, giving the Service's claims priority status. Security State Bank v. IRS (In re Milton Van Gerpen), No. 00-40866 (5th Cir., October 10, 2001). |
| 200148052(PDF, 20K) |
11/30/2001 |
| Issues: (1) What is the specific property that may be reached by the § 2057(i)(3)(P) lien? Does this lien reach personal property as well as real property? (2) How should the Form 668H Notice of Federal Estate Tax Lien be completed in order to reach this property? (3) Are there any methods to effectively encumber the transfer of stock in a closely-held corporation other than filing the Form 668H? (4) Are the qualified heirs personally liable for any additional estate tax which may arise under § 2057(f)? Do others with an interest in the property subject to the § 2057(i)(3)(P) lien consent to collection of any additional estate tax from the property? |
| 200148051(PDF, 43K) |
11/30/2001 |
| Issues: (1) Does a failed Roth IRA conversion result in a distribution from the traditional IRA, including the imposition of the additional tax on early distributions, and the imposition of a six percent excise tax on excess contributions to the Roth IRA? (2) Does the Taxpayer Advocate have any discretion to allow a taxpayer to recharacterize a failed Roth IRA conversion after the deadline for recharacterizing an IRA contribution? 3: How should the taxes and penalties attributable to a failed Roth IRA conversion be assessed and collected against a taxpayer? |
| 200148050(PDF, 12K) |
11/30/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200148049(PDF, 16K) |
11/30/2001 |
| This is in response to a letter dated February 21, 2001, in which rulings were requested as to the federal income tax consequences of a proposed transaction. Additional information was submitted on May 21, May 22, June 14, June 27, July 24, and July 25, 2001. |
| 200148048(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective February 9, 2001, and that ceased to be an employer under the Acts effective February 9, 2001. |
| 200148047(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective February 9, 2001, and that ceased to be an employer under the Acts effective February 9, 2001. |
| 200148046(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following businesses became employers under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective October 1, 2000. |
| 200148045(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200148044(PDF, 13K) |
11/30/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200148043(PDF, 7.2K) |
11/30/2001 |
| Requesting a ruling that X be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as a corporation for federal tax purposes under § 301.7701-3(c). |
| 200148042(PDF, 11K) |
11/30/2001 |
| Requesting rulings as to various factors relating to qualification of Taxpayer to serve as an exchange accommodation titleholder, pursuant to Rev. Proc. 2000-37, 2000-40 I.R.B. 308. |
| 200148041(PDF, 10K) |
11/30/2001 |
| Request a ruling on the application of the generation-skipping transfer tax provisions of Chapter 13 of the Internal Revenue Code to the proposed modification of Trust 1 and Trust 2. |
| 200148040(PDF, 14K) |
11/30/2001 |
| This responds to a ruling request dated April 24, 2001, submitted on behalf of the County by its authorized representative, concerning whether line of duty disability benefits paid to disabled participants in the Plan are excludable from the gross income of the recipients under § 104(a)(1) of the Internal Revenue Code. |
| 200148039(PDF, 33K) |
11/30/2001 |
| This Chief Counsel Advice responds to your memorandum dated December 13, 2000. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200148038(PDF, 12K) |
11/30/2001 |
| This letter is in response to a request submitted by your representative on March 9, 2000 for a ruling that A is a political subdivision of Tribe. |
| 200148037(PDF, 14K) |
11/30/2001 |
| Requesting a private letter ruling providing that the failure to file notices of certain transactions under former Temp. Reg. §7.367(b)-1(c), in effect for the years of the transactions, was due to reasonable cause within the meaning of §7.367(b)-1(c)(3). |
| 200148036(PDF, 14K) |
11/30/2001 |
| Requesting a private letter ruling providing that the failure to file notices of certain transactions under former Temp. Reg. §7.367(b)-1(c), in effect for the years of the transactions, was due to reasonable cause within the meaning of §7.367(b)-1(c)(3). |
| 200148035(PDF, 15K) |
11/30/2001 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200148034(PDF, 12K) |
11/30/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax (GSTT) consequences of a court ordered modification of Trust. |
| 200148033(PDF, 5.9K) |
11/30/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200148032(PDF, 9.0K) |
11/30/2001 |
| Requesting a ruling that X's rental income from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200148031(PDF, 19K) |
11/30/2001 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200148030(PDF, 10K) |
11/30/2001 |
| Fund requests a ruling that it will not recognize gain or loss under § 852(b)(6) of the Internal Revenue Code of 1986 upon the distribution of stock and securities in redemption of shares of Fund upon the request of a shareholder. |
| 200148029(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective January 1, 2001. |
| 200148028(PDF, 21K) |
11/30/2001 |
| Requesting rulings on the proper tax treatment of the income of an irrevocable trust ( Trust ) under § 671 of the Internal Revenue Code and the federal gift tax consequences of contributions to the Trust. |
| 200148027(PDF, 6.0K) |
11/30/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200148026(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that was an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act (the Acts), from April 1, 2000 until December 13, 2000; and that became an employer under the Acts effective December 13, 2000. |
| 200148025(PDF, 47K) |
11/30/2001 |
| Issue: Whether the location savings provision under § 3.02(3) of Rev. Proc. 63-10 applies to allocations of income and expenses related to goods manufactured and sold to a domestic corporation by its wholly-owned manufacturing subsidiary located in Puerto Rico when the subsidiary has in effect a cost sharing method election under § 936(h)(5)(C)(i). Whether an island affiliate that manufactures Components and Products that are ultimately sold by its mainland affiliate at an overall loss and applies the cost plus or comparable profits method to determine allocations for market returns on routine contributions under the first step of the residual profit split method may, in the second step, allocate operating loss with respect to intangibles to the island affiliate and, thus, decrease the transfer price below the amount determined under § 3.02(3) of Rev. Proc 63-10. |
| 200148024(PDF, 14K) |
11/30/2001 |
| Requesting a ruling that the rental income to be received by New Corporation from Properties after a proposed restructuring is not passive investment income as defined under § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200148023(PDF, 14K) |
11/30/2001 |
| Requesting a ruling that the rental income to be received by New Corporation from Properties after a proposed restructuring is not passive investment income as defined under § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200148022(PDF, 26K) |
11/30/2001 |
| Issues: (1) Whether Taxpayer, a title insurance company, is required to issue Forms 1099 for commissions paid to its independent agents? (2) If the answer to Issue 1 is no, whether Taxpayer is nonetheless required to issue Forms 1099 for commissions paid to independent agents who are also attorneys? |
| 200148021(PDF, 14K) |
11/30/2001 |
| Requesting a ruling that the rental income to be received by New Corporation from Properties after a proposed restructuring is not passive investment income as defined under § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200148020(PDF, 14K) |
11/30/2001 |
| This letter is in response to a request submitted by your representative on June 14, 2000, as amended by a letter dated August 21, 2001, for a ruling that College A is an integral part of Tribe A. |
| 200148019(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act and that service performed by its employees are not covered under the Acts. |
| 200148018(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective March 1, 2001. |
| 200148017(PDF, 6.1K) |
11/30/2001 |
| Letter requesting permission for Taxpayer to revoke its election under § 41(c)(4). |
| 200148016(PDF, 41K) |
11/30/2001 |
| Issues: (1) Whether a correlative adjustment 1 pursuant to Treasury Regulation § 1.482-1(g) should be made in the instant case, and if so, what is the correlative adjustment to be made? (2) How would notice of the correlative adjustment be communicated, and who would execute the document for the Service (considering the fact that the position of "District Director" referenced in the regulation no longer exists)? (3) If a refund for "the other taxpayer" would be produced by the correlative adjustment, can the statute of limitations for filing a claim defeat that benefit? |
| 200148015(PDF, 34K) |
11/30/2001 |
| Taxpayer filed the Form 3115 to request permission to change its method of computing depreciation for street lighting equipment under Rev. Proc. 97-37, 1997-2 C. B. 55. Because this change was under an automatic consent revenue procedure, Taxpayer has already made this change. |
| 200148014(PDF, 14K) |
11/30/2001 |
| This letter responds to your request for a private letter ruling on behalf of Taxpayer. Taxpayer is a regulated public utility that owns an undivided fee simple interest as a tenant in common in a nuclear power plant (the plant) and certain other facilities and assets associated therewith and ancillary thereto. For federal income tax purposes Taxpayer files a consolidated return with an affiliated group which includes Common Parent (the consolidated group). |
| 200148013(PDF, 14K) |
11/30/2001 |
| This letter responds to your request for a private letter ruling on behalf of Taxpayer. Taxpayer is a regulated public utility that owns an undivided fee simple interest as a tenant in common in a nuclear power plant (the plant) and certain other facilities and assets associated therewith and ancillary thereto. For federal income tax purposes Taxpayer files a consolidated return with an affiliated group which includes Common Parent (the consolidated group). |
| 200148012(PDF, 13K) |
11/30/2001 |
| This letter responds to your request for a private letter ruling on behalf of Taxpayer. Taxpayer is a regulated public utility that owns an undivided fee simple interest as a tenant in common in a nuclear power plant (the plant) and certain other facilities and assets associated therewith and ancillary thereto. Taxpayer maintains a decommissioning fund (qualified fund) that satisfies the requirements necessary to be treated as a "nuclear decommissioning reserve fund" within the meaning of § 468A(a)1, and as a "nuclear decommissioning fund" and a "qualified nuclear decommissioning fund" within the meaning of Treasury Regulation § 1.468A-1(b)(3). |
| 200148011(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective November 9, 2000. |
| 200148010(PDF, 14K) |
11/30/2001 |
| A request for a ruling under § 172(f)(3). |
| 200148009(PDF, 13K) |
11/30/2001 |
| This letter responds to your request for a private letter ruling on behalf of Taxpayer. |
| 200148008(PDF, 32K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective February 1, 2001. |
| 200148007(PDF, 18K) |
11/30/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased being an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective November 8, 2000. |
| 200148006(PDF, 37K) |
11/30/2001 |
| Issue: Whether the proposed treatment of Taxpayer's contributions to an irrevocable grantor trust to fund an employee bonus plan is appropriate under the developed facts and cInternal Revenue Codeumstances of this case. |
| 200148005(PDF, 24K) |
11/30/2001 |
| Partial withdrawal of request for change in accounting method. |
| 200148004(PDF, 23K) |
11/30/2001 |
| This Chief Counsel Advice responds to your memorandum dated April 12, 2001. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200148003(PDF, 14K) |
11/30/2001 |
| This letter responds to your request for a private letter ruling on behalf of Taxpayer. |
| 200148002(PDF, 35K) |
11/30/2001 |
| This letter responds to your letter dated May 7, 2001, and subsequent correspondence submitted on behalf of Taxpayer, requesting a letter ruling concerning whether amounts contributed by State to Taxpayer in connection with the development and construction of a natural gas transmission and distribution system are nonshareholder contributions to capital excludable from income under § 118(a) of the Internal Revenue Code. |
| 200148001(PDF, 7.9K) |
11/30/2001 |
| Requesting a supplemental ruling to PLR 100247-00, a ruling letter issued on June 7, 2000 ( Prior Ruling Letter ). |
| 200147059(PDF, 74K) |
4/12/2002 |
| We have considered your request for rulings as to the consequences of several proposed transactions on your exempt status under § 501(c)(3) of the Internal Revenue Code and your classification as other than a private foundation under § 509(a) of the Code. |
| 200147058(PDF, 67K) |
4/12/2002 |
| This is in response to letters dated May 23 and July 31, 2001, and previous correspondence submitted by your authorized representatives on behalf of M and its title holding corporations, requesting a ruling on the proper treatment under § 512 of the Internal Revenue Code of certain payments M and its title holding corporations intend to receive in connection with the provision of telecommunications services, telecommunications related services, and utility services. |
| 200147057(PDF, 48K) |
4/12/2002 |
| We have considered M's ruling request dated May 22, 2001. M requests a ruling that a proposed set-aside of funds, as described in detail below, will qualify as an appropriate set-aside under § 4942(g)(2) of the Internal Revenue Code and § 53.4942(a)-3(b) of the Foundation and Similar Excise Taxes Regulations on the basis that the proposed set-aside satisfies the suitability test of § 53.4942(a)-3(b)(2). |
| 200147056(PDF, 77K) |
4/12/2002 |
| This is in response to a request for a private letter ruling submitted by your authorized representatives and dated January 28, 1999, as supplemented by correspondence dated April 23, 1999, August 20, 1999, February 17, 2000, April 28, 2000, January 17, 2001, and April 10, 2001, concerning the tax consequences of certain transactions. Your authorized representatives have submitted the following facts and representations in support of your request. |
| 200147055(PDF, 29K) |
4/12/2002 |
| This is in response to a ruling request dated XX, as supplemented by additional correspondence dated XX, from your authorized representative, concerning the pick up of certain employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200147054(PDF, 36K) |
4/12/2002 |
| This is in response to a ruling request dated xxxxxx, as supplemented by additional correspondence dated xxxxxx, and xxxxxx, from your authorized representative, concerning the pick up of certain employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200147053(PDF, 31K) |
11/28/2001 |
| Issues: (1) If a taxpayer decides to make an election under § 1033(a)(2) of the Internal Revenue Code for a taxable year after he has already filed an income tax return for that year, must he file an amended return prior to expiration of the replacement period (as defined in § 1033(a)(2)(B)) or may he file it within the regular period of limitations for filing claims for refund as set forth in § 6511? (2) If a taxpayer decides to make an election under § 1033(a) for a taxable year after he has filed an income tax return for that year, may he designate as replacement property qualifying property that he acquired prior to making the election? (3) May a taxpayer amend his income tax return for a taxable year to designate as replacement property qualifying property that he acquired during that year, if he has made an election under § 1033(a) but did not designate such property, or any other qualifying property, on his original return? |
| 200147052(PDF, 24K) |
11/28/2001 |
| Issues: The requested rulings involve (1) whether contracts under which Company provides coverage for certain products against mechanical breakdown (beyond the warranties provided by the manufacturer or retailer) qualify as insurance contracts, and (2) whether Company will be treated as an insurance company for federal income tax purposes. |
| 200147051(PDF, 7.3K) |
11/28/2001 |
| Ruling request on behalf of the Authority concerning the use of average area purchase price limitations based upon more accurate and comprehensive data than that used to calculate the safe harbor limitations published in Rev. Proc. 94-55, 1994-2 C.B. 706. |
| 200147050(PDF, 9.2K) |
11/28/2001 |
| 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. |
| 200147049(PDF, 6.9K) |
11/28/2001 |
| Requesting a ruling, under § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations, that B be granted an extension of time for making an election to be disregarded as an entity separate from its owner for federal tax purposes. |
| 200147048(PDF, 6.9K) |
11/28/2001 |
| Requesting a ruling, under § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations, that B be granted an extension of time for making an election to be disregarded as an entity separate from its owner for federal tax purposes. |
| 200147047(PDF, 5.8K) |
11/28/2001 |
| Requesting a ruling on behalf of X under § 1362(b)(5) of the Internal Revenue Code. |
| 200147046(PDF, 9.3K) |
11/28/2001 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200147045(PDF, 9.3K) |
11/28/2001 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200147044(PDF, 13K) |
11/28/2001 |
| Requesting rulings under §§ 678 and 1361 of the Internal Revenue Code. |
| 200147043(PDF, 14K) |
11/28/2001 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200147042(PDF, 13K) |
11/28/2001 |
| Request for a ruling on the application of the generation-skipping transfer tax provisions of Chapter 13 of the Internal Revenue Code to the proposed modification to Trust. |
| 200147041(PDF, 13K) |
11/28/2001 |
| Purchaser and Seller are requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200147040(PDF, 9.2K) |
11/28/2001 |
| We have been asked to rule 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. |
| 200147039(PDF, 9.8K) |
11/28/2001 |
| Requesting a ruling concerning the estate tax consequences under § 2042 of the Internal Revenue Code of certain language contained in an irrevocable life insurance trust (Trust 2). |
| 200147038(PDF, 10K) |
11/28/2001 |
| Requesting rulings under §§ 1362(g) and 1362(b)(5) of the Internal Revenue Code. |
| 200147037(PDF, 49K) |
11/28/2001 |
| Issues: (1) Whether the foreign economic process requirements of § 924(d) were met for intercompany product sale transactions recorded by the taxpayer's commonly-owned U.S. companies simultaneously with the taxpayer's sale of the product to unrelated foreign customers in a transaction in which a foreign sales corporation (FSC) acted as the taxpayer's commission agent. (2) Whether the taxpayer's method of computing a FSC commission met the requirements of the administrative pricing method of § 925(a)(2). |
| 200147036(PDF, 6.1K) |
11/28/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200147035(PDF, 11K) |
11/28/2001 |
| Issue: Whether this case is an appropriate vehicle for establishing that package and graphic design costs are capital expenditures. |
| 200147034(PDF, 14K) |
11/28/2001 |
| This letter is in response to your letter dated December 13, 2000, and subsequent correspondence submitted on behalf of Company, requesting a ruling under §§ 1362(d)(3) and 1375(a) of the Internal Revenue Code. |
| 200147033(PDF, 28K) |
11/28/2001 |
| Issues: This Field Service Advice addresses the character and source under the U.S.-Country A income tax treaty of guarantee fees paid by Taxpayer to A, its foreign parent corporation. The following issues are presented: 1) How are guarantee fees paid by Taxpayer in the United States to A in Country A characterized, sourced and subjected to tax under the Internal Revenue Code? 2) Are the guarantee fees characterized as interest under Article A of U.S.-Country A income tax treaty? 3) Are the guarantee fees Industrial and Commercial Profits to A, that are exempt from U.S. tax under the U.S.-Country A Income Tax Treaty? |
| 200147032(PDF, 24K) |
11/28/2001 |
| Issue: (1) If Corp A barters advertising time on its television station for the right to broadcast a television series or feature films, under the accrual method of accounting, when must the advertising income be accrued? 2) If Corp A barters advertising time on its television station for the right to broadcast a television series or feature films, under the accrual method of accounting, when are the resulting deductions incurred and in what amount? |
| 200147031(PDF, 7.5K) |
11/28/2001 |
| 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. |
| 200147030(PDF, 21K) |
11/28/2001 |
| Request 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") because Taxpayer recently acquired the Plant from Seller. |
| 200147029(PDF, 21K) |
11/28/2001 |
| Request 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") because Taxpayer recently acquired the Plant from Seller. |
| 200147028(PDF, 33K) |
11/28/2001 |
| This is in response to your letter dated March 30, 2001, and prior correspondence requesting, on behalf of Taxpayers, rulings under §§ 61, 1001, and 2601 of the Internal Revenue Code. |
| 200147027(PDF, 21K) |
11/28/2001 |
| Request, 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") because Taxpayer recently acquired the Plant from Seller. |
| 200147026(PDF, 8.0K) |
11/28/2001 |
| This letter responds to your February 22, 2001, request for a private letter ruling, submitted on behalf of X requesting that X be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c) to be treated as a corporation for federal tax purposes. |
| 200147025(PDF, 21K) |
11/28/2001 |
| Request 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") because Taxpayer recently acquired the Plant from Seller. |
| 200147024(PDF, 21K) |
11/28/2001 |
| This letter responds to your request, dated December 12, 2000, and subsequent submission, 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") because Taxpayer recently acquired the Plant from Seller. |
| 200147023(PDF, 9.9K) |
11/28/2001 |
| This is in reply to the private letter ruling request in which the taxpayer requests an extension of time to make an election under § 108(c) of the Internal Revenue Code. Specifically, the taxpayer has requested an extension of time to make an election under § 108(c) and § 1.108(c)-1 of the Income Tax Regulations to reduce the basis of depreciable property and to exclude income resulting from the discharge of qualified real property business indebtedness. |
| 200147022(PDF, 19K) |
11/28/2001 |
| Issues: Does the issuance of the Financing Order authorizing the collection of the TBCs and the issuance of the Recovery Order authorizing the collection of the Tax Charges result in gross income to Company? Does the issuance of the Transition Bonds result in gross income to Company? Are the Transition Bonds obligations of Company? |
| 200147021(PDF, 7.7K) |
11/28/2001 |
| Issue: Is the deemed gift under § 2515 of the generation-skipping transfer tax imposed on a direct skip split between spouses if the spouses have elected under § 2513 to split all gifts made to third parties during the calendar year? |
| 200147020(PDF, 6.1K) |
11/28/2001 |
| Requesting that X be given an extension of time in which to elect to be treated as an association taxable as a corporation for federal tax purposes as of D1. |
| 200147019(PDF, 6.1K) |
11/28/2001 |
| Requesting that X be given an extension of time in which to elect to be treated as an association taxable as a corporation for federal tax purposes as of D1. |
| 200147018(PDF, 6.1K) |
11/28/2001 |
| Requesting that X be given an extension of time in which to elect to be treated as an association taxable as a corporation for federal tax purposes as of D1. |
| 200147017(PDF, 18K) |
11/28/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective November 27, 2000. |
| 200147016(PDF, 18K) |
11/28/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective February 13, 2001. |
| 200147015(PDF, 12K) |
11/28/2001 |
| This responds to your request for a ruling that the bonds of the Project Issue will not be issued earlier than necessary for purposes of § 1.148-10(a)(4) of the Income Tax Regulations. |
| 200147014(PDF, 10K) |
11/28/2001 |
| This is in response to a request submitted by State for an extension of time under § 301.9100-1 of the Procedure and Administrative Regulations to file an amended Form 8328 (Carryforward Election of Unused Private Activity Bond Volume Cap) in order to make a carryforward election under § 146(f) of the Internal Revenue Code. |
| 200147013(PDF, 44K) |
11/28/2001 |
| This Field Service Advice responds to your memorandum dated March 9, 2001. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200147012(PDF, 30K) |
11/28/2001 |
| Issue: Whether Taxpayer may deduct the value of land previously received by it tax-free under the Alaska Native Claims Settlement Act (ANCSA) and conveyed to City as required by § 14(c)(3) of ANCSA. |
| 200147011(PDF, 9.6K) |
11/28/2001 |
| Taxpayer is requesting a private letter ruling that the redemption of tax-exempt bonds at any time on or after the date on which Project C is placed in service for purposes of § 42 of the Internal Revenue Code will not preclude a determination that Project C was financed with the proceeds of tax-bonds under § 42(h)(4)(B), provided the requirements of § 42(h)(4) are otherwise satisfied. |
| 200147010(PDF, 9.9K) |
11/28/2001 |
| Taxpayer is requesting a private letter ruling that the redemption of the tax-exempt bonds at any time on or after the date on which Project C is placed in service for purposes of § 42 of the Internal Revenue Code will not preclude a determination that the Project was financed with the proceeds tax-exempt bonds under § 42(h)(4)(B), provided the requirements of § 42(h)(4) are otherwise satisfied. |
| 200147009(PDF, 9.7K) |
11/28/2001 |
| Taxpayer is requesting a ruling that the redemption of tax-exempt bonds at any time on or after the date on which Project A is placed in service for purposes of § 42 of the Internal Revenue Code will not preclude a determination that Project A was financed with the proceeds of tax-exempt bonds under § 42(h)(4)(B). |
| 200147008(PDF, 9.4K) |
11/28/2001 |
| Taxpayer is requesting a private letter ruling that the redemption of the tax-exempt bonds at any time on or after the date on which Project E is placed in service for purposes of § 42 of the Internal Revenue Code will not preclude a determination that the Project was financed with the proceeds of tax-exempt bonds under § 42(h)(4)(B). |
| 200147007(PDF, 15K) |
11/28/2001 |
| Issue: Whether a foreign life insurance company carrying on an insurance business in the U.S. determines the amount of income effectively connected with its U.S. business under § 842(a) of the Internal Revenue Code based exclusively on the amount of income reported by the business on the National Association Insurance Commissioner's ("NAIC") annual statement filed with the state insurance commissioner. |
| 200147006(PDF, 36K) |
11/28/2001 |
| Issues: (1) Are former school superintendents who provide administrative services to school districts under contract with a corporation properly classified as employees for purposes of taxes under the Federal Insurance Contributions Act (FICA)? (2) Do Old-Age, Survivors and Disability Insurance (OASDI) tax and Medicare tax apply to former school superintendents under these facts? |
| 200147005(PDF, 32K) |
11/28/2001 |
| Issue: Were interest and late payment penalty charges properly imposed when the taxpayer paid the tax under § 565(e) of the Internal Revenue Code with its Form 1120, filed on September 12, 1997 pursuant to an extension to file. |
| 200147004(PDF, 6.7K) |
11/28/2001 |
| This replies to a letter dated July 3, 2001, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file annual certifications pursuant to former Treas. Reg. § 1.367(a)-3T(g)(5)(i) for Tax Years (1) and (2). |
| 200147003(PDF, 18K) |
11/28/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective August 23, 2000. |
| 200147002(PDF, 18K) |
11/28/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective August 1, 2000. |
| 200147001(PDF, 18K) |
11/28/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective October 14, 1997. |
| 200146058(PDF, 16K) |
11/17/2001 |
| Issue: Where a corporate Chapter 11 plan has been confirmed and the taxpayer-debtor fails to make one or more scheduled payments under the plan, is the Service entitled to collect the entire amount due under the plan or only the amount in default? |
| 200146057(PDF, 41K) |
11/28/2001 |
| We have reviewed the proposed Memorandum of Understanding (MOU) between the IRS and the Nebraska Department of Revenue, Charitable Gaming Services, concerning the conduct of joint civil and criminal tax investigations and the sharing of tax information between the two agencies. |
| 200146056(PDF, 22K) |
11/17/2001 |
| Issues: 1) What is the Service's tax law position pursuant to Internal Revenue Code § 446(e) in each of the following cInternal Revenue Codeumstances? 2) Before proposing compliance with I.R.C. § 446(e) in any of the following cInternal Revenue Codeumstances is it necessary for Service personnel (e.g., examiners, appeals officers, field counsel) to establish "tax avoidance"? 3) What is the precedential value to taxpayers and Service personnel of FSA 200102004 relative to the I.R.C. § 446(e) issues outlined below? |
| 200146055(PDF, 5.5K) |
11/17/2001 |
| This is in response to the letter submitted by X's authorized representative dated, requesting a ruling that Article 21 of the United States-Country A income tax treaty ( Treaty ) is applicable, and that X's employees are not subject to U.S. income tax. |
| 200146054(PDF, 12K) |
11/17/2001 |
| This responds to your Authorized Representative's May 11, 2001 letter submitted on behalf of Successor (as successor to Taxpayer), requesting an extension of time under 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election under § 1.337(d)-5T(b) and (c), to be subject to the rules of § 1374 with respect to assets that Taxpayer held on Date B. |
| 200146053(PDF, 12K) |
11/17/2001 |
| Purchaser and Seller, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200146052(PDF, 24K) |
11/17/2001 |
| Withdrawal of request for ruling letter after adverse opinion reached. |
| 200146051(PDF, 9.6K) |
11/17/2001 |
| This responds to your letter dated July 19, 2001, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200146050(PDF, 6.6K) |
11/17/2001 |
| This replies to a letter dated September 19, 2000, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement provided under § 1.1503-2(g)(2)(i) with respect to Entity for the tax year ended on Date D. |
| 200146049(PDF, 5.9K) |
11/17/2001 |
| This letter responds to a letter dated March 30, 2001, and subsequent correspondence, submitted by you on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200146048(PDF, 12K) |
11/17/2001 |
| Purchaser and Seller 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)-1T(c) of the Income Tax Regulations with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date B. |
| 200146047(PDF, 23K) |
11/17/2001 |
| This Chief Counsel Advice responds to your memorandum dated April 23, 2001. In accordance with § 6110(k)(3) of the Internal Revenue Code, this Chief Counsel Advice should not be cited as precedent. |
| 200146046(PDF, 21K) |
11/17/2001 |
| This Chief Counsel Advice responds to your memorandum dated April 23, 2001. In accordance with § 6110(k)(3) of the Internal Revenue Code, this Chief Counsel Advice should not be cited as precedent. |
| 200146045(PDF, 19K) |
11/17/2001 |
| This is in response to a letter dated February 22, 2001, and subsequent correspondence, requesting a ruling regarding the generation-skipping transfer tax (GSTT) consequences of the severance and modification of Trust. |
| 200146044(PDF, 5.9K) |
11/17/2001 |
| This letter responds to a letter, dated June 19, 2001, submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200146043(PDF, 18K) |
11/17/2001 |
| Issues: (1) The State's proposed use of proceeds of the Bonds (a use that if tested separately, would not meet § 141(a) of the Internal Revenue Code of 1986) will not cause less than 95 percent of the net proceeds of the Bonds to be used to provide an exempt facility under § 142(a); and (2) The proposed use of the proceeds of the Bonds will not cause § 147(f) to be violated. |
| 200146042(PDF, 21K) |
11/17/2001 |
| We received a letter and subsequent correspondence from your representative submitted on your behalf requesting rulings regarding the continuing need to maintain the Trust reserve fund and any generation-skipping transfer tax consequences under § 2601, et. seq. of the Internal Revenue Code resulting from reallocating the income paid into the Trust reserve fund among the Trust beneficiaries. |
| 200146041(PDF, 5.8K) |
11/17/2001 |
| This letter responds to your letter, dated June 12, 2001, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200146040(PDF, 5.9K) |
11/17/2001 |
| This responds to a letter dated May 21, 2001, and subsequent correspondence, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200146039(PDF, 10K) |
11/17/2001 |
| This letter responds to your letter dated May 11, 2001, on behalf of X, requesting an extension of time under § 301.9100 of the Procedure and Administrative Regulations for X to elect to treat certain subsidiaries as qualified subchapter S subsidiaries (QSubs) under § 1361(b)(3) of the Internal Revenue Code. |
| 200146038(PDF, 5.9K) |
11/17/2001 |
| This letter responds to a letter dated June 13, 2001, submitted on behalf of X by X's authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200146037(PDF, 6.6K) |
11/17/2001 |
| This letter responds to your representative's letter dated September 11, 2000, and subsequent correspondence, written on behalf of X, requesting a ruling that X's S corporation status will be effective as of D1. |
| 200146036(PDF, 6.1K) |
11/17/2001 |
| This letter responds to a letter dated June 22, 2001, and additional correspondence, submitted on behalf of X by X's authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200146035(PDF, 8.2K) |
11/17/2001 |
| This is in response to a letter from your authorized representative dated April 27, 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. Additional information was submitted in a letter dated June 14, 2001. |
| 200146034(PDF, 6.4K) |
11/17/2001 |
| This letter responds to a letter dated March 28, 2001, by your authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200146033(PDF, 21K) |
11/17/2001 |
| Request Concerning Method of Accounting for Transportation and Material Handling Costs Related to Coal Used to Produced Electricity. |
| 200146032(PDF, 7.5K) |
11/17/2001 |
| This letter responds to a letter dated March 30, 2001, from your authorized representative, as well as subsequent correspondence, submitted on behalf of Company, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200146031(PDF, 6.2K) |
11/17/2001 |
| This letter responds to your letter dated January 24, 2001, on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200146030(PDF, 9.4K) |
11/17/2001 |
| This letter responds to your letter dated February 26, 2001, as well as additional correspondence, submitted on behalf of Company, requesting a ruling under § 1362(f) of the Internal Revenue Code that Company's S corporation election was inadvertently invalid. |
| 200146029(PDF, 8.7K) |
11/17/2001 |
| This letter responds to a letter dated March 29, 2001, and subsequent correspondence written on behalf of Z, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be classified as a partnership under § 301.7701-3(c). |
| 200146028(PDF, 36K) |
11/17/2001 |
| Issues: (1) Whether, under the facts summarized below, Taxpayer's "incremental cost" method of cost allocation for income tax purposes is a reasonable allocation method that clearly reflects Taxpayer's income for the taxable years at issue. (2) If Taxpayer's cost allocation method is not a reasonable allocation method, what is a reasonable allocation method under the facts described below? |
| 200146027(PDF, 6.8K) |
11/17/2001 |
| This letter responds to a letter dated February 21, 2001, from your authorized representative, as well as subsequent correspondence, requesting an extension of time for Company to elect under § 1361(b)(3)(B) of the Internal Revenue Code to treat Corp as a qualified subchapter S subsidiary (Q Sub). |
| 200146026(PDF, 23K) |
11/17/2001 |
| Issues: (1) If the Service requires the use of the calendar year as the taxable year, has the period of limitations expired for calendar years 1993, 1994, and 1995? (2) If the Service accepts the use of the years ended September 30, 1993, September 30, 1994, and September 30, 1995, has the period of limitations for assessing tax for those years expired? |
| 200146025(PDF, 57K) |
11/17/2001 |
| Issues: The issues taken from your request for Field Service Advice (FSA) are as follows: (1) Whether the Taxpayer is entitled to a deduction of $B for losses claimed on the sale of the Custodial Share Receipts in Year X. (2) Whether the Parent is required to report income in Year X from holding the Custodial Share Receipts. |
| 200146024(PDF, 14K) |
11/17/2001 |
| Issue: Is the fabrication of semitrailer bodies under the cInternal Revenue Codeumstances described below the manufacture of a new body for purposes of the tax imposed by § 4051 of the Internal Revenue Code and, if so, who is liable for the tax? |
| 200146023(PDF, 7.0K) |
11/17/2001 |
| This letter responds to your June 15, 2001, request for a private letter ruling, submitted on behalf of X, requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200146022(PDF, 8.3K) |
11/17/2001 |
| This is in response to a letter from your authorized representative dated March 1, 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. |
| 200146021(PDF, 7.8K) |
11/17/2001 |
| This replies to a letter dated October 30, 2000, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement and certifications described in § 1.1503-2(g)(2)(i) with respect to Entity for the tax year ended on Date D1. |
| 200146020(PDF, 41K) |
11/17/2001 |
| This letter is in reply to your letter dated December 19, 2000, requesting rulings as to the federal income tax consequences of a proposed transaction. |
| 200146019(PDF, 19K) |
11/17/2001 |
| We respond to your letter dated February 22, 2001, in which rulings are requested regarding the federal income tax consequences of a proposed transaction. |
| 200146018(PDF, 13K) |
11/17/2001 |
| This is in response to your letter dated April 12, 2001. In your letter you requested permission to revoke an election under § 1.163(d)-1(c) of the Income Tax Regulations to treat capital gains as investment income under § 163(d)(1) and 163(d)(4)(B)(iii) of the Internal Revenue Code for Year 1 (the "Election"). |
| 200146017(PDF, 6.2K) |
11/17/2001 |
| This responds to a letter dated May 18, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200146016(PDF, 4.6K) |
11/17/2001 |
| The taxpayer has requested that the Form 1128 be considered timely filed under the authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200146015(PDF, 11K) |
11/17/2001 |
| This is in response to your letter dated February 13, 2001, and subsequent correspondence, in which you requested an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make a qualified domestic trust ("QDOT") election pursuant to § 2056A(d) of the Internal Revenue Code . |
| 200146014(PDF, 24K) |
11/17/2001 |
| This letter responds to the request of Taxpayer, dated February 23, 2001, for a revised schedule of ruling amounts in accordance with § 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on July 19, 1990. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to § 1.468A-3(h)(2). |
| 200146013(PDF, 33K) |
11/17/2001 |
| This Chief Counsel Advice responds to your memorandum dated October 4, 2000. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200146012(PDF, 9.0K) |
11/17/2001 |
| This is in reply to your letter dated January 4, 2001, and subsequent correspondence, requesting rulings on behalf of Taxpayer concerning the Federal income tax treatment under § 104 and 105 of the Internal Revenue Code of long-term disability benefits paid through the Plan. |
| 200146011(PDF, 8.8K) |
11/17/2001 |
| Requesting rulings on behalf of Taxpayer concerning the Federal income tax treatment under § 104 and 105 of the Internal Revenue Code of long-term disability benefits paid through the Plan. |
| 200146010(PDF, 10K) |
11/17/2001 |
| Requesting rulings on behalf of Taxpayer concerning the Federal income tax treatment under § 104 and 105 of the Internal Revenue Code of long-term disability benefits paid through the Plan. |
| 200146009(PDF, 16K) |
11/17/2001 |
| Taxpayer sought permission to change its accounting method for certain coal transportation costs. |
| 200146008(PDF, 28K) |
11/17/2001 |
| Issue: Whether the characterization or allocation of certain payments made by the taxpayer pursuant to the settlement of a lawsuit is fixed by the terms of the settlement agreement entered into by the parties to the litigation. |
| 200146007(PDF, 18K) |
11/17/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act and services performed by its employees are not services covered under the Acts. |
| 200146006(PDF, 25K) |
11/17/2001 |
| This is in response to your request for a ruling concerning the Worker's status for federal employment tax purposes with respect to services he performs for the Town. |
| 200146005(PDF, 18K) |
11/17/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200146004(PDF, 18K) |
11/17/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective June 1, 2000. |
| 200146003(PDF, 18K) |
11/17/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective December 11, 1998. |
| 200146002(PDF, 18K) |
11/17/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective November 1, 1997. |
| 200146001(PDF, 21K) |
11/17/2001 |
| Issue: Whether the French research tax credit is a credit within the meaning of Treasury Regulation §1.901-2(e)(2)(i) and, therefore, reduces the amount of foreign income TAM-103376-01 taxes paid by the French CFCs for foreign tax credit purposes. |
| 200145042(PDF, 81K) |
11/9/2001 |
| On September 25, 2001, the United States Supreme Court agreed to hear two cases of interest to the Service: United States v. Craft and Young v. United States. |
| 200145041(PDF, 32K) |
11/9/2001 |
| Issue: Whether the Philadelphia Service Center ("PSC") should certify the residency of a common trust fund for treaty purposes at the entity level or the participant level. |
| 200145040(PDF, 95K) |
11/9/2001 |
| This memorandum supplements our memorandum to you dated April 19, 2000, in which we discussed the handling of Federal Insurance Contributions Act ("FICA") refund claims that have been filed nation-wide involving medical residents. |
| 200145039(PDF, 8.2K) |
11/9/2001 |
| Requested rulings on the federal income tax consequences of a completed transaction and a proposed transaction under § 368(a)(1)(A). |
| 200145038(PDF, 6.0K) |
11/9/2001 |
| This responds to a letter, dated March 29, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200145037(PDF, 5.5K) |
11/9/2001 |
| This responds to a letter dated March 13, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200145036(PDF, 6.0K) |
11/9/2001 |
| This responds to a letter dated June 13, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200145035(PDF, 5.7K) |
11/9/2001 |
| This responds to your letter dated June 6, 2001, submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200145034(PDF, 8.7K) |
11/9/2001 |
| This letter responds to a letter dated April 19, 2001, and earlier correspondence, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200145033(PDF, 8.7K) |
11/9/2001 |
| This letter responds to a letter dated April 19, 2001, and earlier correspondence, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200145032(PDF, 4.7K) |
11/9/2001 |
| This letter responds to a letter, dated September 27, 2000, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200145031(PDF, 6.1K) |
11/9/2001 |
| This responds to a letter dated July 17, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200145030(PDF, 6.8K) |
11/9/2001 |
| This responds to the letter dated May 7, 2001, together with subsequent correspondence, submitted on behalf of X, requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to elect to treat Y as a qualified subchapter S subsidiary for federal tax purposes. |
| 200145029(PDF, 11K) |
11/9/2001 |
| We respond to your authorized representative's letter of February 6, 2001, requesting rulings on the federal income tax consequences of a proposed transaction. |
| 200145028(PDF, 10K) |
11/9/2001 |
| This responds to a letter dated December 18, 2000, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200145027(PDF, 8.3K) |
11/9/2001 |
| This letter responds to a letter dated May 24, 2001, written on behalf of X, requesting a ruling that X be granted an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to elect to treat its first tier subsidiary, Y, as a qualified subchapter S subsidiary (Q Sub). |
| 200145026(PDF, 6.7K) |
11/9/2001 |
| This responds to a letter dated March 13, 2001, submitted on behalf of X, requesting a ruling that from D1 to D2 X had only one class of stock within the meaning of § 1361(b)(1)(D) of the Internal Revenue Code. |
| 200145025(PDF, 7.5K) |
11/9/2001 |
| This responds to your authorized representative's letter dated June 22, 2001 requesting relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200145024(PDF, 8.6K) |
11/9/2001 |
| This letter responds to your letter, received June 6, 2001, and subsequent correspondence, requesting an extension of time for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. |
| 200145023(PDF, 5.8K) |
11/9/2001 |
| This letter responds to a letter dated March 7, 2001, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200145022(PDF, 8.5K) |
11/9/2001 |
| This letter responds to a letter dated April 14, 2001, requesting an extension of time for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. X represents the following facts. |
| 200145021(PDF, 8.5K) |
11/9/2001 |
| This is in response to A's letter dated May 14, 2001 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. |
| 200145020(PDF, 9.3K) |
11/9/2001 |
| This letter responds to your letter dated February 20, 2001, and subsequent correspondence submitted on behalf of Company, requesting inadvertent invalid election relief under § 1362(f) of the Internal Revenue Code. |
| 200145019(PDF, 10K) |
11/9/2001 |
| This responds to the February 3, 2001 letter, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200145018(PDF, 6.0K) |
11/9/2001 |
| This letter responds to a letter received March 19, 2001, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200145017(PDF, 6.4K) |
11/9/2001 |
| This letter responds to your letter, dated February 16, 2001, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200145016(PDF, 12K) |
11/9/2001 |
| Requesting an extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200145015(PDF, 6.0K) |
11/9/2001 |
| This letter responds to a letter dated March 26, 2001, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200145014(PDF, 6.4K) |
11/9/2001 |
| This letter responds to a letter, dated January 24, 2001, requesting a ruling on behalf of X under § 1362(b)(5) of the Internal Revenue Code that X's S corporation election will be effective as of the taxable year beginning D. |
| 200145013(PDF, 50K) |
11/9/2001 |
| Issues: (1) Whether certain credit card fee income received by an Issuer may be treated as interest income? (2) Whether an Issuer making a change in method of accounting with respect to pools of credit card receivables under § 12.02 of the Appendix to Rev. Proc. 98-60 may include more than grace period interest? |
| 200145012(PDF, 17K) |
11/9/2001 |
| This letter responds to the request on behalf of Taxpayer, dated, for a revised schedule of ruling amounts in accordance with § 1.468A-3(i)(2) of the Income Tax Regulations relating to the Plant's nuclear decommissioning fund ( Fund ). |
| 200145011(PDF, 53K) |
11/9/2001 |
| Issue: Whether the expenditures paid by Taxpayer to A for research and development are "research and experimental expenditures" incurred in connection with Taxpayer's trade or business under Internal Revenue Code § 174. |
| 200145010(PDF, 24K) |
11/9/2001 |
| Issue: The sole issue set forth in your Field Service Advice (FSA) request is whether Taxpayer is permitted to deduct the built-in loss on the Old Swaps where they are closed out by entering into off-market New Swaps with excess fixed rate payments to cover the built-in loss. |
| 200145009(PDF, 18K) |
11/9/2001 |
| Issues: (1) Whether the transfer of assets from Sub 1 to Sub 3 qualifies as a reorganization under § 368(a)(1)(F). (2) If the transaction qualifies as an F reorganization, whether Sub 3 must reduce the basis of the assets it received from Sub 1 pursuant to §§108 and 1017. |
| 200145008(PDF, 10K) |
11/9/2001 |
| This is in response to your authorized representative's letter dated April 4, 2001, requesting a ruling on behalf of Parent that, under § 1504(a)(3)(B) of the Internal Revenue Code (the "Code"), the Service waive the general rule of § 1504(a)(3)(A) of the Code. Additional information was received in a letter dated May 14, 2001. |
| 200145007(PDF, 17K) |
11/9/2001 |
| This letter responds to the request on behalf of Taxpayer, dated for a revised schedule of ruling amounts in accordance with § 1.468A-3(i)(2) of the Income Tax Regulations relating to the Plant's nuclear decommissioning fund ( Fund ). |
| 200145006(PDF, 10K) |
11/9/2001 |
| This is in response to your letter of December 15, 2000 and subsequent correspondence requesting a ruling with respect to X's Deferred Compensation Plan which X intends to be an eligible deferred compensation plan under § 457 of the Internal Revenue Code of 1986 . |
| 200145005(PDF, 20K) |
11/9/2001 |
| Issue: Whether a note can be characterized as debt when all interest payments due thereon must be paid solely in voting common stock of the issuer, and the principal amount must be paid solely in a fixed number of shares of the issuer's voting common stock determined on the date the note was issued? |
| 200145004(PDF, 14K) |
11/9/2001 |
| Issue: Whether the tax benefit rule entitles A to exclude from taxable income the portion of settlement proceeds relating to Year 1 through Year 9 when A was exempt from federal income tax. |
| 200145003(PDF, 27K) |
11/9/2001 |
| Issue: Are costs incurred by Taxpayer to modify certain leases capital expenditures under § 263 of the Internal Revenue Code or deductible expenses under § 162? |
| 200145002(PDF, 52K) |
11/9/2001 |
| Issue: Whether the series of transactions involving Equipment is a financing arrangement or a sale-leaseback. |
| 200145001(PDF, 29K) |
11/9/2001 |
| Issues: This is in reply to your letter of January 24, 2000, and additional correspondence dated May 26, 2000, July 5, 2000, July 7, 2000, and September 20, 2000, requesting rulings on the reinvestment of proceeds under § 1033 of the Internal Revenue Code. Specifically, Taxpayer seeks rulings that (1) the Taxpayer's relinquishment of real property was under the "threat or imminence of condemnation" and therefore qualifies as an involuntary conversion under § 1033, and that (2) the real property was "held for productive use in a trade or business or for investment" by the Taxpayer under § 1033(g)(1). |
