Chief Counsel's Written Determinations Issued from 200305000 to 200309999

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.

200309031(PDF, 343K)	12/4/2002
Request for a ruling regarding the federal tax consequences. Fact: 0 is a community hospital located in (1) 0 is recognized as exempt from federal income tax under § 501(c)(3) of the Internal Revenue Code and is classified as other than a private foundation under § 509(a)(l) and 170(b)(l)(A)(iii) of the Code.
200309030(PDF, 495K)	12/4/2002
Request relief under § 301.9100-3 of the Procedure and Administration Regulations.
200309029(PDF, 419K)	12/2/2002
Request relief under § 301.91 00-3 of the Procedure and Administration Regulations.
200309028(PDF, 380K)	12/2/2002
Request regarding whether distributions from IRA Z will be considered substantially equal periodic payments for purposes of § 72(t)(2)(A)(iv) of the Internal Revenue Code and that the commencement of distributions from IRA Z will not result in a modification to the stream of substantially equal periodic payments from IRA Y.
200309027(PDF, 789K)	12/2/2002
Request, as supp,zmented, for rulings under § 4941 of the Code and § 501 (c)(3) of the Code.
200309026(PDF, 20K)	2/28/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer exemption.
200309025(PDF, 11K)	2/28/2003
Requesting a ruling that A’s loss of lawful permanent resident status (expatriation) 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 April 26, 2002. T
200309024(PDF, 27K)	2/28/2003
Requesting rulings under § 29 and 702 of the Internal Revenue Code.
200309023(PDF, 12K)	2/28/2003
Requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A’s loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200309022(PDF, 14K)	2/28/2003
Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code.
200309021(PDF, 13K)	2/28/2003
Requesting rulings under §§ 1362(d)(3) and 1375 of the Internal Revenue Code.
200309020(PDF, 22K)	2/28/2003
Requested and submitted in letters dated August 2, September 25, October 3 and 25, and November 12, 2002.
200309019(PDF, 14K)	2/28/2003
Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code.
200309018(PDF, 13K)	2/28/2003
Requesting inadvertent termination relief under §1362(f) of the Internal Revenue Code.
200309017(PDF, 9K)	2/28/2003
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that Company's late election under § 1362(a) to be an S corporation will be treated as timely made.
200309016(PDF, 9K)	2/28/2003
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that Company's late election under § 1362(a) to be an S corporation will be treated as timely made.
200309015(PDF, 9K)	2/28/2003
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that Company's late election under § 1362(a) to be a S corporation will be treated as timely made.
200309014(PDF, 9K)	2/28/2003
In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year. Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending December 31, to a taxable year ending October 31, effective October 31, 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.
200309013(PDF, 8K)	2/28/2003
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200309012(PDF, 8K)	2/28/2003
Requesting under § 301.9100-3 of the Procedure and Administration Regulations an extension of time to file a request for a revised schedule of ruling amounts for Plant under § 1.468A-3(i)(1)(i) of the Income Tax Regulations for the period beginning D2 and ending D3.
200309011(PDF, 8K)	2/28/2003
Requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200309010(PDF, 20K)	2/28/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Taxpayer’s generation-skipping transfer exemption.
200309009(PDF, 10K)	2/28/2003
Requesting a private letter ruling regarding § 42 of the Internal Revenue Code.
200309008(PDF, 8K)	2/28/2003
Requested relief under §1362(b)(5) of the Internal Revenue Code.
200309007(PDF, 21K)	2/28/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Taxpayer’s generation-skipping transfer exemption.
200309006(PDF, 15K)	2/28/2003
Requested, on behalf of Trust, an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to file the notice provided under § 20.2056A-10(a)(2) of the Estate Tax Regulations, that the beneficiary of Trust has become a United States citizen.
200309005(PDF, 22K)	2/28/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer Tax exemption.
200309004(PDF, 8K)	2/28/2003
Requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200309003(PDF, 40K)	2/28/2003
Request on behalf of the Issuer for the following rulings: (1) The Organization’s contracts with Agency 1 and Agency 2, both of which are agencies of the United States, will not result in private business use of the Facility (hereinafter defined) to be financed with the proceeds of the Bonds for purposes of § 141(b) and 145 of the Internal Revenue Code. (2) Payments to the Organization under the contracts with Agency 1 and Agency 2 will not cause the Bonds to be federally guaranteed within the meaning of § 149(b) of the Code.
200309002(PDF, 11K)	2/28/2003
Issue: Whether Taxpayer, a truck retailer, is liable for the tax imposed by § 4051(a) of the Internal Revenue Code on its sale of trucks purchased from Manufacturer.
200309001(PDF, 9K)	2/28/2003
Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending March 31, to a taxable year ending December 31, effective December 31, 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.
200308055(PDF, 346K)	12/11/2002
Request dated August 17, 1999, concerning the tax treatment of certain set asides and contributions to the VEBA, which is a welfare benefit fund established by the Company.
200308054(PDF, 500K)	12/10/2002
Request relief under § 301.91 00-3 of the Procedure and Administration Regulations. The following facts and representations were made in support of your ruling request.
200308053(PDF, 319K)	11/27/2002
Request concerning the pick up of employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code.
200308052(PDF, 356K)	11/26/2002
Requested certain rulings with respect to a proposed transfer of all of the assets of B to C, D and E.
200308051(PDF, 364K)	11/26/2002
Requested certain rulings with respect to a proposed transfer of all of the assets of B to C, D and E.
200308050(PDF, 366K)	11/26/2002
Requested certain rulings with respect to a proposed transfer of all of the assets of B to C, D and E.
200308049(PDF, 386K)	11/26/2002
Requested certain rulings with respect to a proposed transfer of all of the assets of B to C, D and E.
200308048(PDF, 21K)	2/21/2003
Request for a private letter ruling dated July 17, 2002, submitted by you on behalf of Distributing with respect to the federal income tax consequences of a proposed transaction. The rulings in this letter are based on the facts and representations submitted under penalties of perjury in support of the request. Verification of that information may be required as part of the audit process.
200308047(PDF, 12K)	2/21/2003
Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200308046(PDF, 13K)	2/21/2003
Requesting rulings concerning the income and gift tax consequences of the transaction described below.
200308045(PDF, 14K)	2/21/2003
Requested rulings concerning the generationskipping transfer tax consequences of a judicial modification of an irrevocable trust.
200308044(PDF, 8K)	2/21/2003
Requested relief under § 1362(b)(5) of the Internal Revenue Code.
200308043(PDF, 7K)	2/21/2003
Requested relief under § 1362(b)(5) of the Internal Revenue Code.
200308042(PDF, 10K)	2/21/2003
Requesting permission to revoke an election out of the installment method for the sale of certain property under § 453(d)(3) of the Internal Revenue Code and § 15a.453-1(d)(4) of the Income Tax Regulations.
200308041(PDF, 7K)	2/21/2003
Requesting relief under §1362(b)(5) of the Internal Revenue Code.
200308040(PDF, 8K)	2/21/2003
Requesting a ruling 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 an association taxable as a corporation for federal tax purposes.
200308039(PDF, 8K)	2/21/2003
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200308038(PDF, 11K)	2/21/2003
Requests consent to revoke, for the year ending Date 3 and subsequent years, an election previously made under § 4982(e)(4)(A) of the Internal Revenue Code.
200308037(PDF, 15K)	2/21/2003
Requesting an extension of time under to § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of generationskipping transfer exemption.
200308036(PDF, 11K)	2/21/2003
Requesting relief under § 1362(f) of the Internal Revenue Code.
200308035(PDF, 9K)	2/21/2003
Requesting a ruling regarding X's status as an S corporation. According to the information submitted, X is a State law corporation, which has elected to be treated as an S corporation. X filed returns as an S corporation for Year1 and previous years.
200308034(PDF, 11K)	2/21/2003
Requesting consent to Taxpayer’s revocation of its election under § 831(b) of the Internal Revenue Code to be taxed on only its investment income.
200308033(PDF, 12K)	2/21/2003
Issue: What are the tax consequences to taxpayers of the payment of settlement proceeds for lost fishing income, devaluation of an owner’s fishing permit, and devaluation of fishing boats when the fishing activity is conducted by a corporation or partnership formed either before or after these damages occurred?
200308032(PDF, 26K)	2/21/2003
Requesting rulings on behalf of the Company concerning the treatment under § 817(h) of the Internal Revenue Code of direct investments in certain institutional mutual funds (the “Non-Public Funds”) that are proposed to be made in connection with § 457(b) eligible deferred compensation plans sponsored by tax-exempt entities.
200308031(PDF, 15K)	2/21/2003
Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent and Sellers 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(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.
200308030(PDF, 13K)	2/21/2003
Requesting relief under §1362(b)(5) of the Internal Revenue Code.
200308029(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308028(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308027(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308026(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308025(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308024(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308023(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308022(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308021(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308020(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308019(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308018(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308017(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308016(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308015(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308014(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308013(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308012(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308011(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308010(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308009(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308008(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308007(PDF, 18K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308006(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308005(PDF, 19K)	2/21/2003
Requesting a ruling that B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, S, T, U, V, W, X, Y, and Z, each be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes.
200308004(PDF, 27K)	2/21/2003
Requested with respect to our initial ruling letter dated May 22, 2002.
200308003(PDF, 10K)	2/21/2003
Requesting relief under § 1362(f) of the Internal Revenue Code.
200308002(PDF, 10K)	2/21/2003
Requesting a ruling that X's rental income from its commercial rental properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code.
200308001(PDF, 28K)	2/21/2003
Issue: (1) Is the geothermal deposit for purposes of determining percentage depletion under § 613(e) geothermal brine, geothermal steam or geothermal heat when geothermal brine is converted to steam used in the production of electricity? (2) Where there is no sale of a geothermal resource in the immediate vicinity of the well, must the Taxpayer use a representative market or field price (“RMFP”), if one is available, to calculate its percentage depletion allowance? (3) Where there is no RMFP, and an alternative method is used to determine gross income from the property (“GIFP”) for purposes of computing percentage depletion, should the GIFP be determined by reference to the income actually received? (4) In the absence of an RMFP and under the cInternal Revenue Codeumstances described below, has the Taxpayer determined a reasonable allowance for depletion?
200307097(PDF, 438K)	11/22/2002
This letter is in response to your ruling request dated July 18, 2001 concerning whether Plans X, Y, and 2 qualify as church plans under § 414(e) of the internal Revenue Code.
200307096(PDF, 429K)	11/22/2002
This letter is in response to your ruling request dated July 7, 2001 concerning whether Plan X, Y, and Z qualify as church plans under § 414(e) of the Internal Revenue Code.
200307095(PDF, 417K)	11/21/2002
Regarding distributions from Decedent B’s IRA X to Taxpayer A. Specifically, the rulings requested are whether Taxpayer A is permitted to use his life expectancy to determine the required minimum distributions from IRA X and whether such distributions commenced timely.
200307094(PDF, 835K)	11/20/2002
You requested rulings under § 501 (c)(3) and 511 of the Internal Revenue Code.
200307093(PDF, 422K)	11/19/2002
Request relates to a spinoff involving a cash or deferred arrangement, as described in § 401 (k) of the Internal Revenue Code, from one State governmental entity to another of the same State. L
200307092(PDF, 621K)	11/19/2002
Regarding the federal income tax treatment of certain contributions to Plan X under § 414(h) of the Internal Revenue Code (the ’Code”). submitted on your behalf.
200307091(PDF, 491K)	11/19/2002
Request relief under § 301.91 00-3 of the Procedure and Administration Regulations.
200307090(PDF, 641K)	11/19/2002
Request for a ruling dated November 22, 2000, as supplemented by additional correspondence dated March 22, 2002, August 5, 2002, August 20, 2002, and September 17, 2002, submitted by your authorized representative, as to whether contributions made by Employer A on behalf of certain employees to Plan X are considered contributions by an agency or instrumentality of State M or political subdivision thereof for purposes of § 414(d) of the Internal Revenue Code.
200307089(PDF, 798K)	11/18/2002
Request for a private letter ruling dated and supplemented by letter dated representatives. Agency M is a public transportation agency organized under the laws of State A. Agency M currently maintains Plan X , a defined benefit plan intended to be qualified under the provisions of § 401(a) of the Internal Revenue Code that apply to governmental plans.
200307088(PDF, 19K)	2/14/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer Tax exemption..
200307087(PDF, 13K)	2/14/2003
This Chief Counsel Advice supplements the advice previously issued in this matter on October 31, 2002. In accordance with § 6110(k)(3) of the Internal Revenue Code, this Chief Counsel Advice should not be cited as precedent.
200307086(PDF, 16K)	2/14/2003
Issues: (1) How is the period of limitation on assessment under § 6501(a) determined with respect to a taxpayer making a payment that is subject to the tax imposed by § 4251, 4261, or 4271? (2) Is the answer to (1) affected by any of the following? (a) The taxpayer’s refusal to pay the tax due. (b) The collector’s reporting (or failing to report) a taxpayer’s refusal to pay tax under § 49.4291-1 of the Facilities and Services Excise Tax Regulations. (c) Any agreement by the collector to extend the collector’s period of limitation on assessment. (3) Is the answer to (1) affected by § 6501(e)(3)?
200307085(PDF, 7K)	2/14/2003
This letter responds to a letter dated July 31, 2002, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200307084(PDF, 15K)	2/14/2003
This is in response to your authorized representative's letter of December 31, 2001, and other correspondence and submissions, in which rulings under various § of the Internal Revenue Code of 1986 were requested on your behalf regarding the proper federal income tax treatment of certain transactions between you, X, your employees, and M, as more fully described below. We are pleased to address your concerns.
200307083(PDF, 47K)	2/14/2003
Requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A’s loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200307082(PDF, 15K)	2/14/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer exemption.
200307081(PDF, 29K)	2/14/2003
Requesting a letter ruling concerning whether the transfer of an intertie by Transferor to Taxpayer will be a nonshareholder contribution to capital excludable from income under § 118(a) of the Internal Revenue Code.
200307080(PDF, 30K)	2/14/2003
Requesting rulings under § 331 of the Internal Revenue Code with respect to a proposed transaction.
200307079(PDF, 13K)	2/14/2003
Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code.
200307078(PDF, 15K)	2/14/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer exemption.
200307077(PDF, 68K)	2/14/2003
Issues: (1) Which entity is the proper entity to execute a Form 872 for Company and its subsidiaries for the taxable years ending on Date 1 and Date 2, where Company, the common parent of a consolidated group, has filed for bankruptcy. (2) Who is authorized to sign the Form 872 for Company and its subsidiaries for the taxable years ending on Date 1 and Date 2, where Company, the common parent of a consolidated group, has filed for bankruptcy.
200307076(PDF, 37K)	2/14/2003
Requesting rulings under § 29 and 702 of the Internal Revenue Code.
200307075(PDF, 11K)	2/14/2003
Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Taxpayer to file an election under § 1.1502-21(b)(3)(i) of the Income Tax Regulations to relinquish the entire carryback period for the consolidated net operating loss (“CNOL”) of the consolidated group of which Taxpayer is the common parent for the tax year ended Date 1.
200307074(PDF, 7K)	2/14/2003
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200307073(PDF, 7K)	2/14/2003
Requesting a ruling under § 1362 of the Internal Revenue Code.
200307072(PDF, 11K)	2/14/2003
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200307071(PDF, 7K)	2/14/2003
Requesting a ruling on behalf of Corporation under § 1362(b)(5) of the Internal Revenue Code.
200307070(PDF, 12K)	2/14/2003
Requesting inadvertent invalid election relief under § 1362(f) of the Internal Revenue Code.
200307069(PDF, 7K)	2/14/2003
Subsequent correspondence, submitted on behalf of Company requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200307068(PDF, 10K)	2/14/2003
Requesting a ruling, under § 301.9100-3 of the Procedure and Administration Regulations, that Sub 1 be granted an extension of time for making an election to be treated as a disregarded entity for federal tax purposes under § 301.7701-3(c).
200307067(PDF, 8K)	2/14/2003
Requesting time extensions under § 301.9100-3 of the Procedure and Administration Regulations for X to elect to be classified as an association taxable as a corporation for federal tax purposes.
200307066(PDF, 8K)	2/14/2003
Requesting time extensions under § 301.9100-3 of the Procedure and Administration Regulations for X to elect to be classified as an association taxable as a corporation for federal tax purposes.
200307065(PDF, 17K)	2/14/2003
Issue: You have requested a ruling that Entity is an integral part of State A and contributions to Entity will be deductible under § 170(a) because Entity is described in § 170(c)(1) and § 170(b)(1)(A)(v).
200307064(PDF, 8K)	2/14/2003
Requesting time extensions under § 301.9100-3 of the Procedure and Administration Regulations for X to elect to be classified as an association taxable as a corporation for federal tax purposes.
200307063(PDF, 9K)	2/14/2003
Requesting an extension of time to make an election under § 754 of the Internal Revenue Code.
200307062(PDF, 20K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307061(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307060(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307059(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307058(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307057(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307056(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307055(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307054(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307053(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307052(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307051(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307050(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307049(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307048(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307047(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307046(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307045(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307044(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307043(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307042(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307041(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307040(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307039(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307038(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307037(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307036(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307035(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307034(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307033(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307032(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307031(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307030(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307029(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307028(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307027(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307026(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307025(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307024(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307023(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307022(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307021(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307020(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307019(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307018(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307017(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307016(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307015(PDF, 15K)	2/14/2003
Request for rulings submitted by your representative on behalf of Company and the Selling Shareholders listed on the attached Schedule A, with respect to the transfer of certain water rights. You have requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307014(PDF, 15K)	2/14/2003
Request for rulings submitted by your representative on behalf of Company and the Selling Shareholders listed on the attached Schedule A, with respect to the transfer of certain water rights. You have requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307013(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, you have requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307012(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307011(PDF, 15K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, you have requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307010(PDF, 17K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, you have requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307009(PDF, 17K)	2/14/2003
Requested a ruling that for Federal Income Tax purposes, Company's participation in the procedures by which the transfer of the water is accomplished, in conjunction with the sales by the Selling Shareholders of their rights to the water will not constitute a sale or other disposition of property by Company, nor a distribution of property by the Company to the Selling Shareholders with respect to their stock. Additionally, you have requested rulings on whether the water rights will constitute capital assets “in the hands” of the Selling Shareholders and whether certain sales of these water rights will constitute sales or exchanges of capital assets.
200307008(PDF, 7K)	2/14/2003
Requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200307007(PDF, 9K)	2/14/2003
Requesting a ruling 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 disregarded entity for federal tax purposes.
200307006(PDF, 20K)	2/14/2003
Requested that the Plan, as amended, qualifies as an “employee stock purchase plan,” as defined in § 423(b) of the Internal Revenue Code.
200307005(PDF, 10K)	2/14/2003
Requesting an extension of time 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 and relief under § 1362(b)(5) of the Internal Revenue Code.
200307004(PDF, 16K)	2/14/2003
Request for rulings, submitted by your authorized representative, on behalf of the Corporation that: (1) Bonds issued by the Corporation will be treated as issued on behalf of the State for purposes of § 103 of the Internal Revenue Code, and (2) Bonds may be issued by an entity that is acting on behalf of the State for purposes of Code Section.
200307003(PDF, 56K)	2/14/2003
Request for a ruling under § 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200307002(PDF, 9K)	2/14/2003
Requested a private letter ruling on behalf of Corp X that Corp Y and its pre-acquisition subsidiaries be permitted to change to the tax book value method of asset valuation for purposes of apportioning interest expense for tax years beginning on or after Date 3.
200307001(PDF, 13K)	2/14/2003
Requested rulings under § 302(b)(1) of the Internal Revenue Code concerning the federal income tax consequences of a proposed transaction.
200306039(PDF, 350K)	11/15/2002
Request of October 26, 2001 under § 412(c)(8) of the Internal Revenue Code and § 302(c)(8) of the Employee Retirement Income Security Act of 1974 (ERISA), for approval to retroactively reduce the accrued benefits of plan participants for the above- named defined benefit pension plan, has been denied.
200306038(PDF, 378K)	11/14/2002
Request for rulings on the application of Internal Revenue Code § 412 and 414(f) to the (“the Plan”). The Plan was originally established, as a single-employer plan, December 1, 1997, pursuant to a collective bargaining agreement between the Union and Company A.
200306037(PDF, 9K)	2/7/2003
Requesting a ruling that A’s loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200306036(PDF, 9K)	2/7/2003
Requesting a ruling that A’s loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200306035(PDF, 16K)	2/7/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make a reverse qualified terminable interest property (QTIP) election under § 2652 of the Internal Revenue Code.
200306034(PDF, 9K)	2/7/2003
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200306033(PDF, 17K)	2/7/2003
Requested rulings under § 355 of the Internal Revenue Code. Additional information regarding your request has been submitted in letters dated September 4, September 6, October 10, October 31, November 1, and November 5, 2002.
200306032(PDF, 9K)	2/7/2003
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200306031(PDF, 17K)	2/7/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer exemptions.
200306030(PDF, 11K)	2/7/2003
Requesting on behalf of Company an extension of time pursuant to §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations for Company to elect to treat Subsidiary as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code.
200306029(PDF, 11K)	2/7/2003
Requesting a ruling under § 1362(f) of the Internal Revenue Code that the termination of Company's S corporation election was inadvertent.
200306028(PDF, 14K)	2/7/2003
Requested a ruling under § 2601 of the Internal Revenue Code.
200306027(PDF, 15K)	2/7/2003
Requested a ruling under § 2601 of the Internal Revenue Code.
200306026(PDF, 9K)	2/7/2003
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200306025(PDF, 13K)	2/7/2003
Requesting, on behalf of Taxpayer, an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Taxpayer to file an election under § 1.1502-21(b)(3)(i) of the Income Tax Regulations to relinquish the entire carryback period for the consolidated net operating loss (“CNOL”) of the consolidated group of which the Taxpayer was the common parent for the tax year ending Date (1)
200306024(PDF, 7K)	2/7/2003
Requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200306023(PDF, 19K)	2/7/2003
Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent, as the common parent of an affiliated group of corporations that file a consolidated Federal income tax return, (the “Group” or “Taxpayer”) is requesting an extension to file a “closing-of-the-books election” pursuant to § 1.382-6(b) of the Income Tax Regulations (the “Election”), with respect to a transaction that occurred on Date (1)
200306022(PDF, 8K)	2/7/2003
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200306021(PDF, 7K)	2/7/2003
Requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200306020(PDF, 16K)	2/7/2003
Requesting an extension of time, pursuant to § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations, to make an allocation of the Generation- Skipping Transfer exemption.
200306019(PDF, 7K)	2/7/2003
Requesting relief under §1362(b)(5) of the Internal Revenue Code.
200306018(PDF, 15K)	2/7/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer exemption.
200306017(PDF, 15K)	2/7/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer exemption.
200306016(PDF, 16K)	2/7/2003
Requesting an extension of time, pursuant to § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations, to make an allocation of the Generation- Skipping Transfer exemption.
200306015(PDF, 17K)	2/7/2003
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to allocate Grantor’s and Spouse’s (Taxpayers’) available GST exemption to a transfer to a trust.
200306014(PDF, 23K)	2/7/2003
Requesting rulings on certain federal income tax consequences of a proposed transaction. Distributing is a domestic corporation that was incorporated on Date 1 in State A. Distributing has one class of stock issued and outstanding. Distributing engages in Business A.
200306013(PDF, 9K)	2/7/2003
Requesting a ruling under § 301.9100-(3)(a) of the Procedure and Administration Regulations that P be granted an extension of time to file an election to treat Q as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code, effective Date 1.
200306012(PDF, 12K)	2/7/2003
Request that we supplement our letter ruling dated May 17, 2002 (PLR-163702-01) (the “Prior Letter Ruling”). Capitalized terms not defined in this letter have the meanings assigned them in the Prior Letter Ruling.
200306011(PDF, 9K)	2/7/2003
Requesting a ruling that A’s loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200306010(PDF, 21K)	2/7/2003
Requested rulings with respect to the federal income, gift, and generationskipping transfer tax consequences of a proposed division of two trusts.
200306009(PDF, 20K)	2/7/2003
Requesting rulings concerning the estate tax consequences of the reformation of a trust.
200306008(PDF, 20K)	2/7/2003
Requesting rulings concerning the estate tax consequences of the reformation of a trust.
200306007(PDF, 9K)	2/7/2003
Requesting an extension of time for Company to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be treated as an association taxable as a corporation.
200306006(PDF, 9K)	2/7/2003
Requested relief under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c) for X to be disregarded as an entity separate from its owner.
200306005(PDF, 8K)	2/7/2003
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200306004(PDF, 37K)	2/7/2003
Request on behalf of the Authority for a ruling that the Bonds (hereinafter defined) will not be outstanding longer than necessary to accomplish the governmental purpose of the issue for purposes of § 148 of the Internal Revenue Code.
200306003(PDF, 16K)	2/7/2003
Request for a private letter ruling regarding the applicable qualified project period for the Refunding Bonds
200306002(PDF, 12K)	2/7/2003
Issue: Whether Decedent’s estate is entitled to a charitable deduction under § 2055(a) of the Internal Revenue Code for amounts paid to Charity pursuant to the settlement of a will contest.
200306001(PDF, 52K)	2/7/2003
Request for rulings that: (1) the Issuer is an instrumentality for purposes of § 141 of the Internal Revenue Code; and (2) the Proposed Bonds (hereinafter defined) will be treated as financing property used for governmental purposes under §§ 103 and 141.
200305033(PDF, 260K)	11/6/2002
Requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code.
200305032(PDF, 491K)	11/6/2002
Requesting a series of rulings on your behalf regarding the tax consequences associated with the integration of a hospital and a clinic.
200305031(PDF, 876K)	11/5/2002
Request a private letter ruling that Plan M is a church plan within the meaning of §414(e) of the Internal Revenue Code .
200305030(PDF, 408K)	11/4/2002
Request submitted on your behalf by your authorized representative in which you request a private letter ruling under § 402 of the Internal Revenue Code.
200305029(PDF, 209K)	11/8/2002
This letter constitutes notice that with respect to the above-named defined benefit pension plans (collectively, the “Plans”) we have granted conditional waivers of the minimum funding standards for the respective plan years ended December 31, 2000.
200305028(PDF, 23K)	1/31/2003
Issues: (1) Whether taxpayers who invested in the scheme may treat payments designated as interest they received on promissory notes as a return of capital under the open transaction doctrine or similar principles. (2) Whether the investors are entitled to a theft loss. (3) If the investors are entitled to a theft loss, whether that loss may be claimed when there is a prospect of recovery in a future year.
200305027(PDF, 10K)	1/31/2003
Requests a ruling under Treasury Regulation § 301.9100-3 for an extension of time to satisfy the statement, notice and withholding requirements of § 1.897-2(g), § 1.897-2(h) and § 1.1445-2(c)(3) with respect to the transfers that occurred on Dates A and B.
200305026(PDF, 10K)	1/31/2003
Requesting permission to revoke an election made pursuant to § 761(a) of the Internal Revenue Code that was intended to exclude X from subchapter K of chapter 1 of the Code.
200305025(PDF, 8K)	1/31/2003
Requesting permission to revoke an election made pursuant to § 761(a) of the Internal Revenue Code that was intended to exclude X from subchapter K of chapter 1 of the Code.
200305024(PDF, 18K)	1/31/2003
Requesting a ruling regarding the generation-skipping transfer tax consequences of a proposed modification of a trust.
200305023(PDF, 25K)	1/31/2003
Requesting rulings under §§ 664 and 2055 of the Internal Revenue Code.
200305022(PDF, 15K)	1/31/2003
Requesting, an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of Trustor’s generation-skipping transfer tax exemption to an inter vivos transfer to an irrevocable trust.
200305021(PDF, 18K)	1/31/2003
Requesting a ruling under § 1362(f) of the Internal Revenue Code.
200305020(PDF, 13K)	1/31/2003
Requesting a ruling under § 1362(f) of the Internal Revenue Code.
200305019(PDF, 24K)	1/31/2003
Issues: (1) Under the facts described above, how is it determined which specific portion of the P group’s Year 5 CNOL should be treated as CERT-tainted? (2) Under the facts described above, which rule is applied first: the CNOL apportionment rule of §1.1502-21(b)(2)(iv), or the CERT rule of §172(b)(1)(E) and (h)?
200305018(PDF, 29K)	1/31/2003
Requesting certain rulings under § 72 of the Internal Revenue Code.
200305017(PDF, 13K)	1/31/2003
Requesting rulings with respect to transactions occurring subsequent to the taxpayer’s execution of the transactions in LTR 9704004 (October 23, 1996) and LTR (September 20, 2002, PLR-125782-01)(“PLR- 125782-01").
200305016(PDF, 24K)	1/31/2003
Issue: Whether interest earned on U.S. municipal bonds held by a controlled foreign corporation is properly characterized as foreign personal holding company income, and thus, subpart F income.
200305015(PDF, 13K)	1/31/2003
Requesting a private letter ruling regarding §§ 42 and 263A of the Internal Revenue Code. Specifically, the issue is whether the substitute cost method under Notice 88-99, 1988-2 C.B. 422, may be used to determine eligible basis under § 42.
200305014(PDF, 12K)	1/31/2003
Request on behalf of Taxpayers for a private letter ruling granting permission to revoke an election out of the installment method pursuant to § 453(d) of the Internal Revenue Code.
200305013(PDF, 11K)	1/31/2003
Requesting rulings on behalf of Employer concerning the Federal income tax treatment of long-term disability benefits paid through the Plan under § 104 and 105 of the Internal Revenue Code
200305012(PDF, 7K)	1/31/2003
Requested relief under § 1362(b)(5) of the Internal Revenue Code.
200305011(PDF, 7K)	1/31/2003
Requesting relief under § 1362(b)(5) of the Internal Revenue Code.
200305010(PDF, 23K)	1/31/2003
Request for advice regarding the Service’s obligations under Internal Revenue Code § 7612(c). The Service is conducting an investigation of a large corporate taxpayer. The Service requested copies of computer software, as defined in § 7612, used to calculate elements of the taxpayer’s international tax obligations. The taxpayer expressed a willingness to provide the information voluntarily, however, its contractual agreement with the software provider requires the taxpayer to obtain written assurances from the Service that it will treat the information confidentially. The taxpayer requested that the Service execute a confidentiality agreement.
200305009(PDF, 23K)	1/31/2003
Requesting rulings under §§ 355 and 368 of the Internal Revenue Code with respect to a proposed and partially completed transaction.
200305008(PDF, 31K)	1/31/2003
Issue: In determining the foreign sales corporation (FSC) commission payable by Corp A to Corp A-FSC, whether the taxpayer may group transactions on the basis of product lines that are determined by a selective grouping of “inferior classifications” using the SIC code standard under Temporary Treasury Regulation § 1.925(a)-1T(c)(8)(ii).
200305007(PDF, 32K)	1/31/2003
Issue: Whether amounts designated as royalty payments received by an accountant who performs accounting services should be properly classified as wages.
200305006(PDF, 84K)	1/31/2003
Issue: Whether compulsory contributions made under retirement plans maintained by the Entity and used to purchase retirement annuity contracts described in § 403(b) are wages subject to Federal Insurance Contributions Act (FICA) taxes.
200305005(PDF, 14K)	1/31/2003
Requesting a ruling that the Entity is a political subdivision of State. The Entity was created by State Statute A to manage the medical university hospital and related medical facilities. Control and supervision of the Entity is vested in a board of directors that is identical to the board of the Medical University, which is an integral part of State.
200305004(PDF, 17K)	1/31/2003
Issues: 1) What is the legal effect of the § 6213(d) waiver that was executed by X, when X crossed out the portion of the waiver regarding X’s wishes not to exercise appeal rights or to contest the deficiency amount in the Tax Court. 2) Whether the Tax Court would have jurisdiction over this case to determine the validity of the assessment or the taxes due.
200305003(PDF, 10K)	1/31/2003
PULLED
200305002(PDF, 17K)	1/31/2003
Issue: Whether income of a testamentary trust that is generated by farming activity and distributed by the trust to individuals who are both beneficiaries and trustees of the trust is considered net earnings from self-employment to the individuals and subject to selfemployment tax under § 1402 of the Internal Revenue Code.
200305001(PDF, 16K)	1/31/2003
Issue: Whether income of a QTIP Trust and a Credit Bypass Trust that is generated by farming activity and distributed by the trusts to an individual who is both the beneficiary and trustee of each trust is considered net earnings from self-employment to the individual and subject to self-employment tax under § 1402 of the Internal Revenue Code.

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2003 Chief Counsel'sWritten Determinations

2003 Chief Counsel's
Written Determinations