| 200314031(PDF, 530K) |
1/8/2003 |
| Requested rulings under § 513 and 514 of the Internal Revenue Code. |
| 200314030(PDF, 410K) |
1/6/2003 |
| Requested ruling that any gain realized by it on the sale of certain property, will not cause it to lose it tax exempt status and will not be considered unrelated business taxable income under § 512 of the Internal Revenue Code. |
| 200314029(PDF, 408K) |
1/7/2003 |
| Request concerning the tax consequences of a proposed rollover from tax sheltered annuities described in § 403(b) of the Internal Revenue Code to an individual retirement account following the death of the decedent. |
| 200314028(PDF, 69K) |
4/4/2003 |
| Issues: (1) Are amounts paid for the transportation X provides with its fleet of Internal Revenue Code exempt from the air transportation tax imposed by § 4261 of the Internal Revenue Code by virtue of the exemption provided by § 4281 for small Internal Revenue Code operated on non-established lines? (2) If the transportation at Issue: is not exempt from the § 4261 tax, is X required to collect and pay over to the government the excise tax imposed by § 4261 on amounts paid to X, whether paid by persons purchasing that air transportation directly from X or by persons purchasing that air transportation through third parties? (3) If the transportation at Issue: is not exempt from the § 4261 tax, is X liable for the § 4261 tax by reason of § 4263(c)? |
| 200314027(PDF, 31K) |
4/4/2003 |
| Issues: Whether the Service may abate the remaining tax liabilities for the victims of this conspiracy as well as refund any amounts previously paid for those periods and applied to the outstanding tax liabilities. |
| 200314026(PDF, 29K) |
4/4/2003 |
| Requested ruling that A’s loss of lawful permanent resident status (expatriation) will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Internal Revenue Code. |
| 200314025(PDF, 29K) |
4/4/2003 |
| Requested ruling that A’s loss of lawful permanent resident status (expatriation) will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Internal Revenue Code. |
| 200314024(PDF, 39K) |
4/4/2003 |
| Request for a ruling on behalf of the Authority that the Authority is an instrumentality of one or more political subdivisions of the State for purposes of § 103 and 141 of the Internal Revenue Code. |
| 200314023(PDF, 35K) |
4/4/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent is Requested extension to file a “§ 338 election” under § 338(g) with respect to Purchaser’s acquisition of the stock of Target (hereinafter referred to as the “Election) on Date A. |
| 200314022(PDF, 35K) |
4/4/2003 |
| Requested extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser and Seller are Requested 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, on Date B. |
| 200314021(PDF, 53K) |
4/4/2003 |
| Requested rulings regarding the proposed termination of a charitable remainder unitrust. |
| 200314020(PDF, 32K) |
4/4/2003 |
| Requested 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. |
| 200314019(PDF, 27K) |
4/4/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200314018(PDF, 21K) |
4/4/2003 |
| Requested rulings under § 355, and other §, of the Internal Revenue Code, with respect to proposed transactions involving the taxpayer (Taxpayer) and certain related corporations. |
| 200314017(PDF, 25K) |
4/4/2003 |
| Requested permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200314016(PDF, 28K) |
4/4/2003 |
| Requested ruling under § 1362(f) of the Internal Revenue Code. |
| 200314015(PDF, 23K) |
4/4/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200314014(PDF, 26K) |
4/4/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200314013(PDF, 28K) |
4/4/2003 |
| Requesting that Partnership be granted an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200314012(PDF, 29K) |
4/4/2003 |
| Requested extension of time under § 301.9100 of the Procedure and Administration Regulations to make an inter vivos “qualified terminable interest property” (QTIP) election under § 2523(f) of the Internal Revenue Code with respect to Taxpayer’s Year 1 and Year 2 gifts to Trust. |
| 200314011(PDF, 51K) |
4/4/2003 |
| Requested ruling concerning the generation-skipping transfer tax consequences of the reformation of Child 2's Trust, as described below. |
| 200314010(PDF, 47K) |
4/4/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer tax exemption. |
| 200314009(PDF, 56K) |
4/4/2003 |
| Requested ruling on the application of federal estate tax to the proposed reformation of Trust. |
| 200314008(PDF, 22K) |
4/4/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200314007(PDF, 70K) |
4/4/2003 |
| Requested ruling regarding the income, gift and generation-skipping transfer tax consequences of the proposed merger of two trusts and the subsequent division of the resulting trust. |
| 200314006(PDF, 44K) |
4/4/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to allocate Decedent’s remaining GST exemption to four irrevocable trusts. |
| 200314005(PDF, 31K) |
4/4/2003 |
| Requested extension of time under § 301.9100-1 of the Procedure and Administrative Regulations to file Form 8328 (Carry forward Election of Unused Private Activity Bond Volume Cap) to make a carry forward election under § 146(f) with respect to unused Year 1 volume cap of City. |
| 200314004(PDF, 35K) |
4/4/2003 |
| Requested ruling under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200314003(PDF, 52K) |
4/4/2003 |
| Requested ruling regarding the generation-skipping transfer tax consequences of a proposed judicial modification of a trust. |
| 200314002(PDF, 89K) |
4/4/2003 |
| Requested ruling concerning the proper tax treatment of a transaction fully described below. |
| 200314001(PDF, 27K) |
4/4/2003 |
| Requested extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations for Taxpayer to file an application for certification of historic status with the United States Department of Interior. |
| 200313025(PDF, 11K) |
3/28/2003 |
| Requesting an extension of time under §301.9100-3 of the Procedure and Administration regulations to file an election to be treated as an association taxable as a corporation for federal tax purposes under §301.7701-3(c), effective Date. |
| 200313024(PDF, 420K) |
1/2/2003 |
| Request for a ruling that certain distributions to it from the redemption of tuition certificates under a private prepaid tuition program qualified under § 529 of the Internal Revenue Code as amended by the Economic Growth and Tax Relief Reconciliation Act of 2001, Pub. L. 107-1 6 (the “Act”) will not constitute unrelated business taxable income to I. |
| 200313023(PDF, 624K) |
1/2/2003 |
| Requested a ruling on your behalf under § 414(e) of the Internal Revenue Code. You submitted the following facts and representations request. |
| 200313022(PDF, 751K) |
12/31/2002 |
| Requested certain rulings with respect to a proposed transfer of assets from B to C. B is exempt under § 501 (c)(3) of the Internal Revenue Code and is classified as a private foundation under § 509(a). We have determined that C is tax-exempt under § 501 (c)(3) of the Code and classified as a private foundation under § 509(a) in separate correspondence. |
| 200313021(PDF, 739K) |
12/31/2002 |
| Requested certain rulings with respect to a proposed transfer of assets from B to C. B is exempt under § 501 (c)(3) of the Internal Revenue Code and is classified as a private foundation under § 509(a). We have determined that C is tax-exempt under § 501 (c)(3) of the Code and classified as a private foundation under § 509(a) in separate correspondence. |
| 200313020(PDF, 322K) |
12/3/2002 |
| Requested a ruling on your behalf concerning the federal income tax treatment of certain contributions to Plan X under § 414(h) (2) of the Internal Revenue Code. |
| 200313019(PDF, 874K) |
12/3/2002 |
| Requested rulings on your behalf under § 41 4(e) of the Internal Revenue Code . In support of your ruling requests you have submitted the following statements and information. |
| 200313018(PDF, 15K) |
3/28/2003 |
| Requests, on its own behalf and on behalf of Target, an extension of time under Treasury Regulation § 301.9100-3 to file the following in accordance with Schedule A. |
| 200313017(PDF, 14K) |
3/28/2003 |
| The Entity was created by authorization of State X law, and chartered as a corporation under State X law. The Entity is the only entity, other than the federal government, permitted to conduct Business Y. |
| 200313016(PDF, 52K) |
3/28/2003 |
| Taxpayer represents that it is a life insurance company within the meaning of § 816(a) of the Internal Revenue Code, taxable as such under § 801. |
| 200313015(PDF, 9K) |
3/28/2003 |
| Requesting permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200313014(PDF, 8K) |
3/28/2003 |
| Requesting a ruling that Taxpayer may determine the credit for increasing research activities under the standard method of § 41(a) of the Internal Revenue Code for Taxpayer’s taxable year ending on Date and all subsequent taxable years. |
| 200313013(PDF, 18K) |
3/28/2003 |
| 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. |
| 200313012(PDF, 18K) |
3/28/2003 |
| 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. |
| 200313011(PDF, 10K) |
3/28/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200313010(PDF, 10K) |
3/28/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200313009(PDF, 10K) |
3/28/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200313008(PDF, 23K) |
3/28/2003 |
| 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 Decedent’s generation-skipping transfer exemption to lifetime transfers made to an irrevocable trust. |
| 200313007(PDF, 17K) |
3/28/2003 |
| Request for a ruling that the establishment of a limited partnership and a general partnership by two § 501(c)(3) hospital-related organizations and the use by these partnerships of certain bond-financed property (described below) will not cause the bond-financed property to be treated as owned or used by other than a § 501(c)(3) organization for purposes of §§ 145(a) and 141(b). |
| 200313006(PDF, 11K) |
3/28/2003 |
| Requesting that Company's Form 8716 be considered timely filed under the authority of § 301.9100-3 of the Procedure and Administration Regulations. |
| 200313005(PDF, 10K) |
3/28/2003 |
| Requesting a ruling that Corporation may determine the credit for increasing research activities under the standard method of § 41(a) of the Internal Revenue Code for Corporation’s short taxable year ending on z and all subsequent taxable years. |
| 200313004(PDF, 10K) |
3/28/2003 |
| Requesting a ruling under §1362(b)(5) of the Internal Revenue Code. |
| 200313003(PDF, 24K) |
3/28/2003 |
| Request for rulings regarding certain federal income tax consequences of a proposed transaction. Distributing is engaged in Business A and has voting common and nonvoting common stock outstanding (the “Distributing Voting Stock” and the “Distributing Nonvoting Stock”, respectively, and collectively, the “Distributing Stock”). |
| 200313002(PDF, 25K) |
3/28/2003 |
| Requested rulings concerning the income and generation-skipping transfer (“GST”) tax consequences of the proposed division of an irrevocable trust into two separate and equal successor trusts. |
| 200313001(PDF, 15K) |
3/28/2003 |
| Requesting a ruling under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations. |
| 200312026(PDF, 467K) |
12/23/2002 |
| Request for a letter ruling dated as supplemented by correspondence dated submitted on your behalf by your authorized representative, regarding the federal incomes tax treatment of certain contributions made to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200312025(PDF, 684K) |
8/7/2002 |
| Issue: Is Plan 030 fully funded for the 9312 plan year and subsequent plan years or is there an accumulated funding deficiency, as defined in 5 41 2 of the Internal Revenue Code? |
| 200312024(PDF, 20K) |
3/21/2003 |
| The rulings contained in this letter are based on facts and representations submitted by the taxpayer and accompanied by a penalties of perjury statement executed by an appropriate party. This office has not verified any of the materials submitted in support of the request for rulings. Verification of the information, representations, and other data may be required as part of the audit process. |
| 200312023(PDF, 38K) |
3/21/2003 |
| Requesting rulings under Internal Revenue Code § 368(a)(1)(D) concerning the above named taxpayers. Additional information was received in letters dated October 28, November 25 and December 10, 2002. |
| 200312022(PDF, 23K) |
3/21/2003 |
| Request for rulings regarding certain federal income tax consequences of a proposed transaction. The information submitted in that request and in later correspondences dated October 9, 2002, November 12, 2002 November 21, 2002 and December 6, is summarized below. |
| 200312021(PDF, 13K) |
3/21/2003 |
| Requesting a ruling under § 301.9100-3(a) of the Procedure and Administration Regulations that Y be granted an extension of time to make an election to be treated as a corporation. |
| 200312020(PDF, 13K) |
3/21/2003 |
| Requesting a ruling under § 301.9100-3(a) of the Procedure and Administration Regulations that X be granted an extension of time to make an election to be classified as a corporation. |
| 200312019(PDF, 13K) |
3/21/2003 |
| *PULLED* |
| 200312018(PDF, 14K) |
3/21/2003 |
| Requesting, on behalf of Taxpayer, an extension of time under § 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 Taxpayer’s consolidated group for the tax year ending Date 2. |
| 200312017(PDF, 17K) |
3/21/2003 |
| 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 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)-1(c) of the Income Tax Regulations with respect to Purchaser’s acquisition of the stock of Target 1 and Target 2 (sometimes hereinafter referred to as the “Election”), on Date C. |
| 200312016(PDF, 19K) |
3/21/2003 |
| Issues: Will the waiver by Bank Holding Company of any part of its pro rata share of cash dividends declared by Bank result in gross income to Bank Holding Company under the cInternal Revenue Codeumstances described below? |
| 200312015(PDF, 15K) |
3/21/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Taxpayer and Parent to make a ratable allocation election (the “Election”) under §1.1502-76(b)(2)(ii) of the Income Tax Regulations. |
| 200312014(PDF, 11K) |
3/21/2003 |
| 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 received in a letter dated November 14, 2002. T |
| 200312013(PDF, 15K) |
3/21/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for New Parent and Sub to make an election to file a consolidated Federal income tax return, with New Parent as the common parent, under § 1.1502-75(a)(1) of the Income Tax Regulations (Election), effective for their taxable year ending on Date (1) |
| 200312012(PDF, 24K) |
3/21/2003 |
| Requesting a ruling on behalf of Taxpayer concerning its liability for taxes under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA). Specifically, you have requested a ruling that Taxpayer and the University are deemed related corporations under § 3121(s) of the Internal Revenue Code , as amended by § 125 of Public Law 98-21, and remuneration disbursed by Taxpayer to its healthcare professionals who are concurrently employed by the University is deemed to have been actually disbursed by University as a common paymaster. You have also requested a ruling that Taxpayer is an instrumentality of State X for purposes of § 3306(c)(7) and 3121(b)(7) of the Code. |
| 200312011(PDF, 23K) |
3/21/2003 |
| Requested as to the federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated November 6, November 21, November 22, November 25, and December 4, 2002. |
| 200312010(PDF, 8K) |
3/21/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200312009(PDF, 17K) |
3/21/2003 |
| Requesting a ruling regarding the generation-skipping transfer tax (GSTT) consequences of a judicial construction of Trust. |
| 200312008(PDF, 16K) |
3/21/2003 |
| Requesting a ruling regarding the generation-skipping transfer tax (GSTT) consequences of a judicial construction of Trust. |
| 200312007(PDF, 16K) |
3/21/2003 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of a judicial construction of Trust. |
| 200312006(PDF, 18K) |
3/21/2003 |
| Requesting a ruling regarding the generation-skipping transfer tax (GSTT) consequences of a judicial construction of Trust. |
| 200312005(PDF, 10K) |
3/21/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200312004(PDF, 29K) |
3/21/2003 |
| Issues: (1) Whether the pledge of the options by Corporation constitutes an act of self-dealing between a private foundation and a disqualified person under the provisions of § 4941 of the Code. (2) Whether the exercise of the options by the Foundation pursuant to the Net Exercise procedure will constitute an act of self-dealing between the Foundation and a disqualified person under § 4941 of the Code. (3) Whether the exercise of the options by an unrelated charity will constitute an act of self-dealing between the Foundation and a disqualified person under § 4941 of the Code. (4) Whether any proceeds that the Foundation receives upon the transfer of options to the unrelated charities will be excluded from the computation of the Foundation’s net investment income under § 4940 of the Code. (5) Whether the gain on the Foundation’s exercise of the options through the Net Exercise procedure or sale of the options to an unrelated charity will not be subject to tax on unrelated business taxable income imposed by § 511(a) of the Code. 6.a. If the Foundation transfers the options to an unrelated charitable organization, whether Corporation will be entitled to a charitable contribution deduction under § 170 of the Code upon the exercise of the options by an unrelated charitable organization, and whether such deduction will be for an amount equal to the difference between the exercise price and the fair market value of the Corporation Stock on the date of exercise, subject to the limitations on the amount of a charitable contribution deduction of a corporation under § 170(b)(2) of the Code. 6.b. If the Foundation engages in a Net Exercise of the options, whether Corporation will be entitled to a charitable contribution deduction at the time of the Net Exercise, and whether such deduction will be for an amount equal to the fair market value of the Corporation Stock transferred to the Foundation upon the Net Exercise, subject to the limitations on the amount of a charitable contribution deduction of a corporation under § 170(b)(2) of the Code. |
| 200312003(PDF, 29K) |
3/21/2003 |
| Issues: (1) Whether the pledge of the options by Corporation constitutes an act of self-dealing between a private foundation and a disqualified person under the provisions of § 4941 of the Code. (2) Whether the exercise of the options by the Foundation pursuant to the Net Exercise procedure will constitute an act of self-dealing between the Foundation and a disqualified person under § 4941 of the Code. (3) Whether the exercise of the options by an unrelated charity will constitute an act of self-dealing between the Foundation and a disqualified person under § 4941 of the Code. (4) Whether any proceeds that the Foundation receives upon the transfer of options to the unrelated charities will be excluded from the computation of the Foundation’s net investment income under § 4940 of the Code. (5) Whether the gain on the Foundation’s exercise of the options through the Net Exercise procedure or sale of the options to an unrelated charity will not be subject to tax on unrelated business taxable income imposed by § 511(a) of the Code. 6.a. If the Foundation transfers the options to an unrelated charitable organization, whether Corporation will be entitled to a charitable contribution deduction under § 170 of the Code upon the exercise of the options by an unrelated charitable organization, and whether such deduction will be for an amount equal to the difference between the exercise price and the fair market value of the Corporation Stock on the date of exercise, subject to the limitations on the amount of a charitable contribution deduction of a corporation under § 170(b)(2) of the Code. 6.b. If the Foundation engages in a Net Exercise of the options, whether Corporation will be entitled to a charitable contribution deduction at the time of the Net Exercise, and whether such deduction will be for an amount equal to the fair market value of the Corporation Stock transferred to the Foundation upon the Net Exercise, subject to the limitations on the amount of a charitable contribution deduction of a corporation under § 170(b)(2) of the Code. |
| 200312002(PDF, 11K) |
3/21/2003 |
| *PULLED* |
| 200312001(PDF, 11K) |
3/21/2003 |
| Request dated for a ruling concerning the federal tax treatment under § 104 and 105 of the Internal Revenue Code of long term disability benefits paid under the Plan. |
| 200311043(PDF, 375K) |
12/18/2002 |
| Submitted on your behalf by your authorized representative, in which you request a private letter ruling dealing with the taxability of Employer Vacation Pay Benefit Contributions made to Plan X. |
| 200311042(PDF, 320K) |
12/19/2002 |
| Requesting a series of rulings on your behalf regarding the tax consequences associated with the purchase from and subsequent lease of certain real and personal property to B. |
| 200311041(PDF, 439K) |
12/19/2002 |
| Request from your authorized representative, concerning the pick up of employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200311040(PDF, 268K) |
12/19/2002 |
| Requested rulings on a contingent set-aside under § 53.4242(a)-3(b)(9) of the Foundation and Similar Excise Taxes Regulations. |
| 200311039(PDF, 322K) |
12/19/2002 |
| Requested certain rulings relative to the public charity status of B and C. C is a private, four-year, co-educational liberal arts college. B was formed and organized exclusively to receive and maintain funds, the income and principle of which are used exclusively in support of the charitable and educational goals of C. |
| 200311038(PDF, 325K) |
12/19/2002 |
| Requested certain rulings relative to the public charity status of B and C. C is a private, four-year, co-educational liberal arts college. B was formed and organized exclusively to receive and maintain funds, the income and principle of which are used exclusively in support of the charitable and educational goals of C. |
| 200311037(PDF, 896K) |
12/18/2002 |
| Request dated July 12, 2001, as modified by the letter of December 16, 2002, both submitted on M’s behalf by its authorized representative, wherein M requested that the Service rule as follows: |
| 200311036(PDF, 363K) |
12/18/2002 |
| Request dated August 29, 2002, for a ruling under § 404(a)(6) of the Internal Revenue Code (the ‘‘Cod&’). |
| 200311035(PDF, 85K) |
12/18/2002 |
| (PLR #200241052) You desire that several corrections and clarifications be made to the ruling letter. We are clarifying the following points, all of which are subject to the other terms and conditions of the August 28, 2002 private letter ruling previously issued to you: |
| 200311034(PDF, 2.7M) |
12/17/2002 |
| Request for a ruling that the prepaid tuition plan is a qualified tuition program meeting the requirements of § 529 of the Internal Revenue code. |
| 200311033(PDF, 435K) |
12/16/2002 |
| Requesting that the Commissioner exercise his discretionary authority under § 301.91 00-1 of the Miscellaneous Income Tax Regulations and grant you an extension of time for making a regulatory election as more fully set forth below. |
| 200311032(PDF, 19K) |
3/14/2003 |
| Issue: Do the provisions of § 7602(e) prevent a revenue agent from requesting in an initial interview letter the personal and business bank records from taxpayers who derive a substantial portion of their income from Schedule C and F income where the returns are randomly selected for the National Research Program (NRP)? |
| 200311031(PDF, 8K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311030(PDF, 10K) |
3/14/2003 |
| Requesting certain rulings under the Internal Revenue Code. Effective Date 1, which was after January, 1970 and before October 21, 1979, Individual A entered into Contract B with Company C, and made all contributions to Contract B prior to October 21, 1979. Contract B was intended to function as a deferred annuity contract, subject to § 72 of the Internal Revenue Code, with Individual A as the annuitant. |
| 200311029(PDF, 10K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311028(PDF, 8K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311027(PDF, 9K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200311026(PDF, 8K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311025(PDF, 8K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311024(PDF, 24K) |
3/14/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. Distributing is a State X corporation incorporated in Year A and has engaged in Business A since its formation. Distributing is a calendar year, non-public, subchapter C corporation that uses the cash method of accounting. Distributing is not a member of an affiliated member of a group filing consolidated returns. |
| 200311023(PDF, 30K) |
3/14/2003 |
| Request for rulings on certain federal income tax consequences of a proposed and partially completed transaction (the “Transaction”). |
| 200311022(PDF, 15K) |
3/14/2003 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent is requesting an extension to file a “§ 338 election” under § 338(g) with respect to Purchaser’s acquisition of the stock of Target (sometimes hereinafter referred to as the “Election”). |
| 200311021(PDF, 10K) |
3/14/2003 |
| Requesting a private letter ruling regarding § 45 of the Internal Revenue Code. |
| 200311020(PDF, 28K) |
3/14/2003 |
| Requesting rulings regarding the proper treatment of the Trust under §§ 2041, 2036, 2514, and 2511 of the Internal Revenue Code. |
| 200311019(PDF, 15K) |
3/14/2003 |
| Requesting relief under §1362(f) of the Internal Revenue Code for inadvertent termination of S election. |
| 200311018(PDF, 8K) |
3/14/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200311017(PDF, 8K) |
3/14/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200311016(PDF, 16K) |
3/14/2003 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200311015(PDF, 8K) |
3/14/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200311014(PDF, 8K) |
3/14/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200311013(PDF, 17K) |
3/14/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer exemption. |
| 200311012(PDF, 8K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311011(PDF, 8K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311010(PDF, 10K) |
3/14/2003 |
| Requesting a ruling under § 301.9100-3(a) of the Procedure and Administration Regulations that Corporation A be granted an extension of time to file an election for Corporation B to be a qualified subchapter S subsidiary of Corporation A effective Date 2. |
| 200311009(PDF, 18K) |
3/14/2003 |
| Requesting an extension of time under § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations to make late allocations of Taxpayer’s generation-skipping transfer (“GST”) tax exemption. |
| 200311008(PDF, 14K) |
3/14/2003 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200311007(PDF, 8K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311006(PDF, 8K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311005(PDF, 14K) |
3/14/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200311004(PDF, 8K) |
3/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200311003(PDF, 46K) |
3/14/2003 |
| Issues: (1) Whether a fully integrated oil and gas producer (integrated producer) who owns and operates offshore drilling platforms should classify such platforms under MACRS Asset Guideline Class 13.0, Offshore Drilling, or Asset Guideline Class 13.2, Exploration for and Production of Petroleum and Natural Gas Deposits, of Rev. Proc. 87-56, 1987-2 C.B. 674, for depreciation purposes? (2) If the answer to issue #1 is Asset Guideline Class 13.0 with respect to an offshore drilling platform, whether the Asset Guideline Class changes to 13.2 if and when the drilling platform is converted to one used primarily for the production of oil and gas? |
| 200311002(PDF, 24K) |
3/14/2003 |
| Requesting rulings on certain federal income tax consequences of a proposed transaction. |
| 200311001(PDF, 15K) |
3/14/2003 |
| Requested rulings with respect to whether it may reelect under § 953(d) of the Internal Revenue Code to be treated as a domestic corporation for all purposes of the Code. |
| 200310026(PDF, 19K) |
3/7/2003 |
| Request, for supplemental rulings to PLR-100157-02 (“Prior Ruling”), issued by our office on June 25, 2002. |
| 200310025(PDF, 614K) |
12/13/2002 |
| Submitted on your behalf by your authorized representative, concerning whether Plan X qualifies as a church plan within the meaning of § 414(e) of the Internal Revenue Code. |
| 200310024(PDF, 384K) |
12/12/2002 |
| G is the creator and the non-charitable beneficiary of G Charitable Remainder Trust (Trust), a charitable remainder unitrust.. |
| 200310023(PDF, 504K) |
12/10/2002 |
| Request relief under § 301.91 00-3 of the Procedure and Administration Regulations. |
| 200310022(PDF, 13K) |
3/7/2003 |
| Requesting rulings under § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200310021(PDF, 19K) |
3/7/2003 |
| Requesting rulings under §§ 2501 and 2601 of the Internal Revenue Code. |
| 200310020(PDF, 11K) |
3/7/2003 |
| Requesting a ruling that A’s renunciation of her U.S. citizenship (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. |
| 200310019(PDF, 9K) |
3/7/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200310018(PDF, 8K) |
3/7/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200310017(PDF, 8K) |
3/7/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200310016(PDF, 15K) |
3/7/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer tax exemption. |
| 200310015(PDF, 8K) |
3/7/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200310014(PDF, 20K) |
3/7/2003 |
| Requesting a private letter ruling regarding a trust that has elected to be treated as a real estate investment trust (“REIT”) that owns direct and indirect interests in partnerships and companies that seek to qualify as taxable REIT subsidiaries (“TRSs”). |
| 200310013(PDF, 18K) |
3/7/2003 |
| Requesting an extension of time under § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations to make late allocations of Taxpayer’s generation-skipping transfer (“GST”) tax exemption. |
| 200310012(PDF, 36K) |
3/7/2003 |
| Requesting a letter ruling concerning whether the transfer of an intertie by Generator to Company B is a nonshareholder contribution to capital excludable from Taxpayer’s income under § 118(a) of the Internal Revenue Code. |
| 200310011(PDF, 36K) |
3/7/2003 |
| Requesting a letter ruling concerning whether the transfer of an intertie by Generator to Company B is a nonshareholder contribution to capital excludable from Taxpayer’s income under § 118(a) of the Internal Revenue Code. |
| 200310010(PDF, 10K) |
3/7/2003 |
| 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. |
| 200310009(PDF, 24K) |
3/7/2003 |
| Requesting rulings under Internal Revenue Code §§ 368 and 355. Additional information was received in letters dated October 21 and November 6, 2002. |
| 200310008(PDF, 11K) |
3/7/2003 |
| Requesting a ruling that A’s renunciation of her U.S. citizenship (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. |
| 200310007(PDF, 17K) |
3/7/2003 |
| Requested rulings under various § of the Internal Revenue Code regarding the proper federal income tax treatment (including any reporting and/or withholding obligations) of certain transactions between X, M, and Y (X's employee). |
| 200310006(PDF, 8K) |
3/7/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200310005(PDF, 83K) |
3/7/2003 |
| Request for rulings on certain federal income tax consequences of proposed transactions. |
| 200310004(PDF, 9K) |
3/7/2003 |
| Request for a private letter ruling regarding the late filing of a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer, requesting permission to change its annual accounting period, for federal income tax purposes. The taxpayer is requesting permission to change its annual accounting period from a taxable year ending May 31 to a taxable year ending December 31, effective Date A. 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. |
| 200310003(PDF, 37K) |
3/7/2003 |
| Issues: (1) Whether Taxpayer’s change of reporting income from the sale of certain products is a change in accounting method requiring the Commissioner’s consent or a change in underlying fact. (2) Whether Taxpayer’s present treatment of reporting income from the sale of certain products clearly reflects income for federal income tax purposes. |
| 200310002(PDF, 11K) |
3/7/2003 |
| 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. |
| 200310001(PDF, 21K) |
3/7/2003 |
| Issue: Whether Taxpayer is eligible for the benefits of § 1341 for the payment of damages in a patent infringement lawsuit. |
