| 200324060(PDF, 524K) |
3/18/2003 |
| Request for a letter ruling regarding the federal income tax treatment of certain contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200324059(PDF, 731K) |
3/18/2003 |
| Requested rulings under § 408(d)(3) of the Internal Revenue Code. |
| 200324058(PDF, 518K) |
3/21/2003 |
| Request relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200324057(PDF, 909K) |
3/20/2003 |
| Requested a ruling concerning the application of § 1.6001-1 of the Income Tax Regulations and § 4945 of the Internal Revenue Code. |
| 200324056(PDF, 787K) |
3/20/2003 |
| Requesting a ruling on whether the payment of certain expenses in connection with a conference to be hosted by you for the purpose of evaluating and developing your charitable programs will be taxable expenditures under § 4945 of the Internal Revenue Code. |
| 200324055(PDF, 30K) |
6/13/2003 |
| Requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat Sub 1, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200324054(PDF, 24K) |
6/13/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200324053(PDF, 25K) |
6/13/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200324052(PDF, 24K) |
6/13/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200324051(PDF, 93K) |
6/13/2003 |
| Request a ruling on the application of the income, gift, estate and generation-skipping transfer tax consequences of the proposed division and merger of two trusts. |
| 200324050(PDF, 34K) |
6/13/2003 |
| Requested ruling under § 1362(f) of the Internal Revenue Code. |
| 200324049(PDF, 39K) |
6/13/2003 |
| Requested 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 generation-skipping transfer tax exemptions to transfers to trusts. |
| 200324048(PDF, 30K) |
6/13/2003 |
| Requested extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make an alternate valuation election under § 2032(a) of the Internal Revenue Code. |
| 200324047(PDF, 39K) |
6/13/2003 |
| Request on behalf of Issuer A for a ruling that the Agreement (hereinafter defined) will not cause the property financed by the A Bonds to be treated as owned or used by other than a governmental unit or a § 501(c)(3) organization for purposes of § 145(a) of the Internal Revenue Code.. |
| 200324046(PDF, 26K) |
6/13/2003 |
| Requesting permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200324045(PDF, 27K) |
6/13/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200324044(PDF, 42K) |
6/13/2003 |
| Requested 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 generation-skipping transfer tax exemptions to transfers to trusts. |
| 200324043(PDF, 32K) |
6/13/2003 |
| Request for a ruling to determine the federal employment tax status of the above-named Worker with respect to services provided for a federal agency (Firm) from January 1997, to December 1999. The federal employment taxes are those imposed by FICA, FUTA, and the Collection of Income Tax at Source on Wages. |
| 200324042(PDF, 30K) |
6/13/2003 |
| Requesting a private letter ruling regarding § 42 of the Internal Revenue Code. |
| 200324041(PDF, 44K) |
6/13/2003 |
| Requested 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 Generation-Skipping Transfer exemptions to transfers to a trust. |
| 200324040(PDF, 41K) |
6/13/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser’s Parent is Requested extension to file a “§ 338 election” under § 338(g) with respect to Purchaser’s acquisition of the stock of Target, on Date A (All citations in this letter to regulations under § 338 are to regulations in effect on Date A). |
| 200324039(PDF, 71K) |
6/13/2003 |
| Requested rulings under Internal Revenue Code § 368 and 355. |
| 200324038(PDF, 25K) |
6/13/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200324037(PDF, 41K) |
6/13/2003 |
| Requesting a letter ruling concerning whether the loss of qualified facility (QF) status by Facility would give rise to a deemed transfer of an intertie by Generator to Taxpayer, and if so, if that transfer would be a non-shareholder contribution to capital excludable from Taxpayer’s income under § 118(a) of the Internal Revenue Code. |
| 200324036(PDF, 24K) |
6/13/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200324035(PDF, 58K) |
6/13/2003 |
| Requesting certain rulings regarding the proposed termination of the Trust. |
| 200324034(PDF, 42K) |
6/13/2003 |
| Requesting, on behalf of Taxpayers, 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 Taxpayers’ generation-skipping transfer tax exemptions to transfers made to trusts. |
| 200324033(PDF, 33K) |
6/13/2003 |
| Requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat Sub1 and Sub2 as qualified subchapter S subsidiaries (QSubs) under § 1361(b)(3) of the Internal Revenue Code. |
| 200324032(PDF, 40K) |
6/13/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make timely allocations of generation-skipping transfer exemption with respect to transfers made by Taxpayer to four irrevocable trusts in four different tax years. |
| 200324031(PDF, 40K) |
6/13/2003 |
| Requested extension of time, under § 301.9100-1 and -3 of the Procedure and Administration Regulations, for Taxpayer to make consent dividend elections pursuant to § 565 of the Internal Revenue Code. |
| 200324030(PDF, 31K) |
6/13/2003 |
| Requested ruling that the rental income received by Company from the Property is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200324029(PDF, 33K) |
6/13/2003 |
| Requested ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200324028(PDF, 31K) |
6/13/2003 |
| Requested ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200324027(PDF, 33K) |
6/13/2003 |
| Requested ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200324026(PDF, 31K) |
6/13/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200324025(PDF, 49K) |
6/13/2003 |
| Requested ruling that the repayment of a portion of a bond loan and redemption of a portion of the Project's tax-exempt financing at any time after the date on which the Project is placed in service for purposes of § 42 of the Internal Revenue Code will not, in and of itself, result in a determination that the Project was not financed by tax-exempt bonds for purposes of § 42(h)(4)(B). |
| 200324024(PDF, 50K) |
6/13/2003 |
| Requested rulings for Corporation under § 216, 305, and 311 of the Internal Revenue Code. |
| 200324023(PDF, 57K) |
6/13/2003 |
| Requested rulings on the gift and estate tax consequences of a proposed transaction. |
| 200324022(PDF, 24K) |
6/13/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200324021(PDF, 75K) |
6/13/2003 |
| Requested ruling under § 877(c) of the Internal Revenue Code of 1986 ("Code) that Taxpayer's loss of U.S. permanent resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200324020(PDF, 36K) |
6/13/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser and Sellers 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)-1T(c) of the Income Tax Regulations with respect to Purchaser’s acquisition of the stock of Target, on Date B. |
| 200324019(PDF, 23K) |
6/13/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200324018(PDF, 169K) |
6/13/2003 |
| Requested ruling involving which Taxpayer was the designated beneficiary of Spouse’s IRA. |
| 200324017(PDF, 24K) |
6/13/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200324016(PDF, 26K) |
6/13/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200324015(PDF, 28K) |
6/13/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200324014(PDF, 25K) |
6/13/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200324013(PDF, 88K) |
6/13/2003 |
| Requested ruling on behalf of the above-named taxpayers that, under the facts described below, the taxpayers will have substantially complied with the requirements of § 1042 of the Internal Revenue Code of 1986 and the applicable regulations in connection with the sale of stock of the Company to the employee stock ownership plan (ESOP) maintained by the Company. |
| 200324012(PDF, 20K) |
6/13/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200324011(PDF, 25K) |
6/13/2003 |
| Requested ruling on whether the cost of Surgery is within the definition of “medical care” for purposes of the medical expense deduction under § 213 of the Internal Revenue Code. |
| 200324010(PDF, 34K) |
6/13/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code. |
| 200324009(PDF, 35K) |
6/13/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code. |
| 200324008(PDF, 36K) |
6/13/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code. |
| 200324007(PDF, 35K) |
6/13/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code. |
| 200324006(PDF, 35K) |
6/13/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code. |
| 200324005(PDF, 35K) |
6/13/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code. |
| 200324004(PDF, 34K) |
6/13/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code. |
| 200324003(PDF, 117K) |
6/13/2003 |
| Issue: Under the facts set forth below, is the Taxpayer as a matter of law entitled to the Investment Tax Credit (ITC) under the self-constructed property transition rule of § 203(b)(1)(B) of the Tax Reform Act of 1986 (TRA of 1986). |
| 200324002(PDF, 27K) |
6/13/2003 |
| You have asked for assistance in evaluating whether or not equitable recoupment or mitigation apply in a pending case in the United States Tax Court. |
| 200324001(PDF, 63K) |
6/13/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code, submitted on behalf of Trust. |
| 200323048(PDF, 480K) |
3/13/2003 |
| Requested rulings on your behalf concerning whether Plan M is a church plan described in § 414(e) of the Internal Revenue Code and whether Plan M was so described as of January 1, 1974 and thereafter. |
| 200323047(PDF, 1.9M) |
3/11/2003 |
| Requests involving Issue: under § 507, 4941, 4942 and 4945 of the Code. Specifically, we are responding to your ruling requests relating to the reorganization of two private foundations in existence at the time of your ruling request. |
| 200323046(PDF, 1.9M) |
3/11/2003 |
| Requests involving Issue: under § 507, 4941, 4942 and 4945 of the Code. Specifically, we are responding to your ruling requests relating to the reorganization of two private foundations in existence at the time of your ruling request. |
| 200323045(PDF, 566K) |
3/14/2003 |
| Requested ruling pursuant to § 4943(c)(7) of the Internal Revenue Code, an extension of the 5-year period to dispose of certain excess business holdings acquired by gift or donation. |
| 200323044(PDF, 39K) |
3/12/2003 |
| Request ruling under certain Internal Revenue Code, a disallowance of the deduction of employer contributions to a qualified defined benefit pension plan may be obtained, thereby fulfilling a condition under which such contributions could revert to the employer. This is with respect to the benefit pension plan pursuant to Rev. Proc. 90-49, 1 990-2 C.B. 620, for the plan year commencing January 1, 2002. |
| 200323043(PDF, 129K) |
3/13/2003 |
| This letter constitutes notice that a conditional waiver, in accordance with § 41 2(d) of the Internal Revenue Code and § 303 of the Employee Retirement Income Security Act of 1974 (ERISA), of the minimum funding standard has been granted for the above-named pension plan for the plan year beginning July 23,2001. |
| 200323042(PDF, 42K) |
6/6/2003 |
| Requested ruling under § 1362(f) of the Internal Revenue Code. |
| 200323041(PDF, 52K) |
6/6/2003 |
| Requested rulings on the federal income tax consequences of a proposed transaction. |
| 200323040(PDF, 49K) |
6/6/2003 |
| Requested 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 generation-skipping transfer tax exemptions to transfers to a trust. |
| 200323039(PDF, 25K) |
6/6/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200323038(PDF, 24K) |
6/6/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200323037(PDF, 38K) |
6/6/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer exemptions. |
| 200323036(PDF, 24K) |
6/6/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200323035(PDF, 26K) |
6/6/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200323034(PDF, 63K) |
6/6/2003 |
| Requested that we rule on behalf of Utility, GenCo, and their respective qualified nuclear decommissioning funds, concerning certain tax consequences of the transfer of the Plant from Utility to GenCo, under § 468A of the Internal Revenue Code, in the context of a reorganization of Parent’s business operations. |
| 200323033(PDF, 25K) |
6/6/2003 |
| Requested extension of time under Treasury Regulation § 301.9100-3 to file a waiver provided under § 1.884-2T(a)(2)(i)(D) extending the period for assessment of the branch profits tax for each of Corp A and Corp B for year X until a date not earlier than the last day of year Y. |
| 200323032(PDF, 30K) |
6/6/2003 |
| Requesting that Taxpayer be granted an extension of time under Treasury Regulation § 301.9100-3 to file the election and agreement provided under Treas. Reg. § 1.1503-2(g)(2)(i) for Entity A for Tax Years 1 and 3; and for Entity B for Tax Years 1 and 3; and to file the annual certification provided under § 1.1503-2(g)(2)(vi)(B) for Entity A for Tax Years 2 and 3; and for Entity B for Tax Years 2 and 3. |
| 200323031(PDF, 28K) |
6/6/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200323030(PDF, 29K) |
6/6/2003 |
| Requested ruling under § 877(c) of the Internal Revenue Code of 1986 ("Code) that A’s loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the |
| 200323029(PDF, 37K) |
6/6/2003 |
| Requested ruling concerning A’s loss of lawful permanent resident status (expatriation) and the extent to which gain resulting from the sale of A’s U.S. residence may be excluded. |
| 200323028(PDF, 31K) |
6/6/2003 |
| Your ruling request letter dated November 4, 2002 Requested ruling on a certain federal income tax consequence of a proposed transaction. |
| 200323027(PDF, 36K) |
6/6/2003 |
| Requested ruling concerning A’s loss of lawful permanent resident status (expatriation) and the extent to which gain resulting from the sale of A’s U.S. residence may be excluded. |
| 200323026(PDF, 86K) |
6/6/2003 |
| Issue: (1) Under the Internal Revenue Code below, are amounts paid by a parent corporation and its operating subsidiaries to a related foreign captive insurance company for pollution liability coverage deductible as “insurance premiums” under § 162 of the Internal Revenue Code? (2) Under the Internal Revenue Code below, are amounts paid by a parent corporation and its operating subsidiaries for their respective workers’ compensation coverage to an unrelated insurance company which, in turn, reinsures the risks with a related foreign captive insurance company, deductible as “insurance premiums” under § 162? |
| 200323025(PDF, 51K) |
6/6/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer exemption. |
| 200323024(PDF, 60K) |
6/6/2003 |
| Issue: Whether the Service may levy upon purportedly tax exempt income of an Indian taxpayer? |
| 200323023(PDF, 67K) |
6/6/2003 |
| Request for a ruling to determine the federal employment tax status of the above named Worker with respect to services performed as a park attendant for the Firm, a federal agency, from April 6, 2000 through Sept. 5, 2000. Federal employment taxes are those imposed by the Federal Insurance Contributions Act (FICA), the Federal Unemployment Tax Act (FUTA), and the Collection of Income Tax at Source on Wages. This ruling is based on the information furnished by both the Worker and the Firm. |
| 200323022(PDF, 66K) |
6/6/2003 |
| Request for a ruling to determine the federal employment tax status of the above named Worker with respect to services performed as a park attendant for the Firm, a federal agency, from April 6, 2000 through Sept. 5, 2000. Federal employment taxes are those imposed by the Federal Insurance Contributions Act (FICA), the Federal Unemployment Tax Act (FUTA), and the Collection of Income Tax at Source on Wages. This ruling is based on the information furnished by both the Worker and the Firm. |
| 200323021(PDF, 31K) |
6/6/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200323020(PDF, 27K) |
6/6/2003 |
| Strategic advice memorandum evaluating Taxpayer’s legal argument concerning the application of § 6611(d) and 6513(b)(2) of the Internal Revenue Code. |
| 200323019(PDF, 20K) |
6/6/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200323018(PDF, 33K) |
6/6/2003 |
| Requesting on behalf of Company an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations for Company to elect to be treated as an association taxable as a corporation under § 301.7701-3(c). |
| 200323017(PDF, 35K) |
6/6/2003 |
| Requested ruling that the Plan is an eligible deferred compensation plan within the meaning of § 457 of the Internal Revenue Code of 1986. |
| 200323016(PDF, 33K) |
6/6/2003 |
| Requested a ruling that premiums received by the Taxpayer on policies of insurance or reinsurance of U.S. risks are exempt from the insurance excise tax imposed by § 4371 of the Internal Revenue Code of 1986, as amended (Code), pursuant to the United States-Ireland income tax convention (Treaty). |
| 200323015(PDF, 93K) |
6/6/2003 |
| Requested rulings: (1) The Pool will be classified as a grantor trust under subpart E of part I of subchapter J of Chapter 1 of the Code and that the Partnership will be treated as owning its share of the Obligations held by the Pool; (2) The Partnership will be classified as a partnership for federal income tax purposes; (3) For purposes of § 265(a)(2), the owners of the variable rate certificates and the owners of the residual certificates will be treated as holding their share of the Obligations owned by the Partnership in proportion to their positive capital account balances; (4) Tax-exempt income derived by the Partnership from its interest in the Obligations will have the same character in the hands of holders of the variable rate certificates and residual certificates as in the hands of the Partnership; (5) Allocations of income, gain, loss and deduction provided for in the Partnership agreement will have economic effect; (6) Under § 761(a), the Partnership may elect out of § 706(a) of the Code, and each member of the Partnership may take into account its distributive share of Partnership income, gain, loss and deduction as they are taken into account by the Partnership. |
| 200323014(PDF, 99K) |
6/6/2003 |
| Requesting certain rulings under § 118(a) and 61 of the Internal Revenue Code. |
| 200323013(PDF, 31K) |
6/6/2003 |
| Requested ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200323012(PDF, 43K) |
6/6/2003 |
| Requested ruling under § 72 and 408(d) of the Internal Revenue Code (the "Code). By virtue of the correspondence dated Date 2, our office is not considering the first and second ruling requests contained in your original submission related to § 408(d) of the Code. Those requests were handled separately by letter dated October 29, 2002 (PLR 200304037). |
| 200323011(PDF, 67K) |
6/6/2003 |
| Requested ruling concerning the generation-skipping transfer tax consequences of the proposed transactions. |
| 200323010(PDF, 41K) |
6/6/2003 |
| Requested ruling under § 2056(b)(7) of the Internal Revenue Code. |
| 200323009(PDF, 25K) |
6/6/2003 |
| Requesting permission under Internal Revenue Code § 453(d)(3) and Treasury Regulation § 15A.453-1(d)(4) to revoke the election out of the installment method for a certain sale during the tax year. |
| 200323008(PDF, 77K) |
6/6/2003 |
| Requesting extension of the most recent schedule of ruling amounts for the Fund Issued by the Internal Revenue Service on (the Prior Schedule). The Service limited the Prior Schedule to the years through because, at the time the request for the Prior Schedule was pending with the Service, Taxpayer intended to transfer its ownership interests in the Plant during as part of a corporate reorganization. However, the corporate reorganization did not occur in. Accordingly, Taxpayer is Requested extension of the Prior Schedule ruling amounts. |
| 200323007(PDF, 37K) |
6/6/2003 |
| Requested extension of time pursuant to § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations for Trusts to make an election under § 860(D)(b)(1) of the Internal Revenue Code of 1986 to be treated as a Real Estate Mortgage Investment Conduit (REMIC) for Year 1 and subsequent taxable years. |
| 200323006(PDF, 107K) |
6/6/2003 |
| Requested ruling that the proposed naming rights contract described below (the “Contract) will not cause the Issue: (hereinafter defined) to meet the private business use test under § 141(b) of the Internal Revenue Code (the “Code). |
| 200323005(PDF, 86K) |
6/6/2003 |
| Requesting for an extension of the most recent schedule of ruling amounts for the Fund Issued by the Internal Revenue Service on (the Prior Schedule). The Service limited the Prior Schedule to the years through because, at the time the request for the Prior Schedule was pending with the Service, Taxpayer intended to transfer its ownership interests in the Plant during as part of a corporate reorganization. However, the corporate reorganization did not occur in. Accordingly, Taxpayer is Requested extension of the Prior Schedule ruling amounts. |
| 200323004(PDF, 87K) |
6/6/2003 |
| Requesting for an extension of the most recent schedule of ruling amounts for the Fund Issued by the Internal Revenue Service on (the Prior Schedule). The Service limited the Prior Schedule to the years through because, at the time the request for the Prior Schedule was pending with the Service, Taxpayer intended to transfer its ownership interests in the Plant during as part of a corporate reorganization. However, the corporate reorganization did not occur in. Accordingly, Taxpayer is Requested extension of the Prior Schedule ruling amounts. |
| 200323003(PDF, 28K) |
6/6/2003 |
| Requested ruling under § 301.9100-3(a) of the Procedure and Administration Regulations to file an election for Subsidiary to be treated as a disregarded entity for federal tax purposes. |
| 200323002(PDF, 54K) |
6/6/2003 |
| Issue: Whether the taxpayer properly computed its charitable contribution deduction limitations in accordance with the provisions of Treasury Regulation § 1.1502-47. |
| 200323001(PDF, 25K) |
6/6/2003 |
| Requesting relief under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations for an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200322021(PDF, 112K) |
5/30/2003 |
| Issue: (1) Is the Service’s issuance of a Letter 898, Statement of Proposed Adjustments, to a taxpayer, concerning the taxpayer’s liability for excise tax on the purchase of air transportation or air transportation mileage awards from an air carrier, an examination? (2) Is a subsequent Letter 898 Issued to the taxpayer, concerning the taxpayer’s excise tax liability for the same taxable period for purchases of air transportation or mileage awards from a different carrier, an unnecessary examination for purposes of Internal Revenue Code § 7605(b)? (3) Is a subsequent Letter 898 as described in Issue: 2 a reopening of a closed case subject to the policy and procedures on reopening in Policy Statement P-4-3 (IRM 1.2.1.4.1) and Rev. Proc. 94-68? |
| 200322020(PDF, 466K) |
3/1/2003 |
| Requested ruling concerning the federal income tax treatment of mandatory employee contributions that will be picked up by District X under § 414(h)(2) of the Code. 9 |
| 200322019(PDF, 93K) |
3/6/2003 |
| Requested ruling concerning the applicability of § 41 5(m) of the Internal Revenue Code to an excess plan and the tax consequences of certain related transactions. |
| 200322018(PDF, 111K) |
5/30/2003 |
| Do the Company 1 ADSs that the Taxpayers plan to contribute to the Donees constitute "qualified appreciated stock" within the meaning of § 170(e)(5)(B) of the Internal Revenue Code? |
| 200322017(PDF, 127K) |
5/30/2003 |
| Issue: Whether certain insurance settlement payments received by Taxpayer under third-party Commercial General Liability (CGL) policies are monies received due to an involuntary conversion within the meaning of Internal Revenue Code § 1033(a)(2)? |
| 200322016(PDF, 23K) |
5/30/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200322015(PDF, 44K) |
5/30/2003 |
| Requested 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 Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200322014(PDF, 44K) |
5/30/2003 |
| Requested 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 Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200322013(PDF, 38K) |
5/30/2003 |
| Requested ruling under § 2055 of the Internal Revenue Code. |
| 200322012(PDF, 64K) |
5/30/2003 |
| Requested ruling concerning whether the Plan is a supplemental unemployment benefit (SUB) plan and whether the benefits paid under the Plan are wages subject to the taxes imposed under the Federal Insurance Contributions Act (FICA), the Federal Unemployment Tax Act (FUTA), and the Collection of Income Tax at Source on Wages (federal income tax withholding). |
| 200322011(PDF, 61K) |
5/30/2003 |
| Do the Company 1 ADSs that the Taxpayers plan to contribute to the Donees constitute "qualified appreciated stock" within the meaning of § 170(e)(5)(B) of the Internal Revenue Code? |
| 200322010(PDF, 61K) |
5/30/2003 |
| Do the Company 1 ADSs that the Taxpayers plan to contribute to the Donees constitute "qualified appreciated stock" within the meaning of § 170(e)(5)(B) of the Internal Revenue Code? |
| 200322009(PDF, 62K) |
5/30/2003 |
| Do the Company 1 ADSs that the Taxpayers plan to contribute to the Donees constitute "qualified appreciated stock" within the meaning of § 170(e)(5)(B) of the Internal Revenue Code? |
| 200322008(PDF, 60K) |
5/30/2003 |
| Do the Company 1 ADSs that the Taxpayers plan to contribute to the Donees constitute "qualified appreciated stock" within the meaning of § 170(e)(5)(B) of the Internal Revenue Code? |
| 200322007(PDF, 60K) |
5/30/2003 |
| Do the Company 1 ADSs that the Taxpayers plan to contribute to the Donees constitute "qualified appreciated stock" within the meaning of § 170(e)(5)(B) of the Internal Revenue Code? |
| 200322006(PDF, 61K) |
5/30/2003 |
| Do the Company 1 ADSs that the Taxpayers plan to contribute to the Donees constitute "qualified appreciated stock" within the meaning of § 170(e)(5)(B) of the Internal Revenue Code? |
| 200322005(PDF, 62K) |
5/30/2003 |
| Do the Company 1 ADSs that the Taxpayers plan to contribute to the Donees constitute "qualified appreciated stock" within the meaning of § 170(e)(5)(B) of the Internal Revenue Code? |
| 200322004(PDF, 35K) |
5/30/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations for Purchaser and Seller 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 A. |
| 200322003(PDF, 35K) |
5/30/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations for Purchaser and Seller 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 A. |
| 200322002(PDF, 52K) |
5/30/2003 |
| Issue: Whether services performed by volunteer firefighters in State who are participants in Pension Plan are employment under § 3121(b)(7)(F) of the Code. |
| 200322001(PDF, 19K) |
5/30/2003 |
| *PULLED* |
| 200321026(PDF, 37K) |
2/27/2003 |
| Requested waiver of the minimum funding standard for the plan year ended January 31, 2002. |
| 200321025(PDF, 57K) |
2/27/2003 |
| Requested waiver of the minimum funding standard for the plan year ended December 31, 2001. |
| 200321024(PDF, 494K) |
2/26/2003 |
| Requested ruling concerning the federal income tax treatment of certain contributions made to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200321023(PDF, 944K) |
2/26/2003 |
| Requested ruling regarding the federal income tax consequences of a grant proposed to be made by you to a foreign organization under Internal Revenue Code. |
| 200321022(PDF, 658K) |
2/25/2003 |
| Requested ruling concerning the effect on your status under § 501(c)(3) of the Internal Revenue Code of a grant you are considering making to A, as well as the application of § 4941 and 4945 to this proposed transaction. |
| 200321021(PDF, 728K) |
2/25/2003 |
| Requested ruling relating to the tax consequences flowing from the reorganization of the ownership structure of a wholly-owned for-profit subsidiary, C, and a limited liability company, D, in which C is a member. |
| 200321020(PDF, 605K) |
2/25/2003 |
| Requested ruling concerning the Federal tax consequences of the prepayment of an exempt loan from Company A to Plan X, and the allocation of excess sale proceeds to the accounts of Plan X participants. |
| 200321019(PDF, 652K) |
2/25/2003 |
| Requested ruling with respect to the proposed creation of Plan B and its effect on Plan A. |
| 200321018(PDF, 52K) |
5/23/2003 |
| Requested ruling regarding the application of the Self Employment Contributions Act (SECA) tax to seven scenarios involving the rental of personal property in connection with commercial fishing. In our May 5, 2001, memorandum, we address five of the scenarios (Scenarios #1-4 and #7). This memorandum responds to Scenarios #5 and #6. |
| 200321017(PDF, 25K) |
5/23/2003 |
| Requested advice concerning the effectiveness of a 2848 which lists one attorney and two non-attorneys from one law firm in Part I, paragraph 2, of the 2848. In Part II of the 2848, the attorney has been appropriately self-designated as an attorney by inserting the letter "a" in the left column and signing under penalty of perjury. All other persons have self-designated themselves as "h", "Un-enrolled Return Preparers." |
| 200321016(PDF, 24K) |
5/23/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200321015(PDF, 44K) |
5/23/2003 |
| Request that the Internal Revenue Service rule that the Loan held by REMIC will continue to be a qualified mortgage within the meaning of § 860G(a)(3) of the Internal Revenue Code of 1986 if the real estate collateral that secures Borrower's obligation under the Loan is released from REMIC's lien pursuant to the defeasance transaction described below. |
| 200321014(PDF, 26K) |
5/23/2003 |
| Requested ruling under § 877(c) of the Internal Revenue Code of 1986 ("Code) that A’s loss of U.S. long-term residence will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200321013(PDF, 69K) |
5/23/2003 |
| Requested a ruling and closing agreement that premiums received by Taxpayer on policies of insurance or reinsurance of U.S. risks are exempt from the insurance excise tax imposed by § 4371 of the Internal Revenue Code of 1986, as amended (Code), pursuant to the United States-Ireland Income Tax Convention. |
| 200321012(PDF, 20K) |
5/23/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200321011(PDF, 27K) |
5/23/2003 |
| Requested ruling under § 877(c) of the Internal Revenue Code of 1986 ("Code) that A’s loss of U.S. long-term residence will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200321010(PDF, 47K) |
5/23/2003 |
| Requested ruling regarding the proposed transfer of Company stock to a charitable remainder unitrust (CRUT). |
| 200321009(PDF, 26K) |
5/23/2003 |
| Requested extension of time under Treasury Regulation § 301.9100-3 to file Form 8279, Election To Be Treated as a FSC or as a Small FSC, pursuant to Temp. Treas. Reg. § 1.921-1T(b)(1), Q&A 1, for the tax year beginning on Date A. |
| 200321008(PDF, 33K) |
5/23/2003 |
| Requested extension of time under Treasury Regulation § 301.9100-3 to file agreements required under § 1.1503-2(g)(2)(i) as follows: (i) to permit the inclusion of Entity’s loss in the Corp A consolidated tax return for the tax year ended on Date 1; (ii) to permit the inclusion of Entity’s loss in Taxpayer’s consolidated tax return for the tax years ended on Dates 2 and 3; and to file annual certifications under § 1.1503-2(g)(2)(vi) as follows: (iii) for the tax year ended on Date 2 with respect to Entity’s loss incurred in the tax year ended on Date 1; and (iv) for the tax year ended on Date 3 with respect to Entity’s loss incurred in the tax years ended on Dates 1 and 2. |
| 200321007(PDF, 24K) |
5/23/2003 |
| Requested ruling that Taxpayer be granted an extension of time under Treasury Regulation § 301.9100-3 to elect the foreign earned income exclusion for the tax years at Issue. |
| 200321006(PDF, 36K) |
5/23/2003 |
| Requested ruling regarding the application of § 6166 of the Internal Revenue Code to certain transactions. Specifically, you have asked us to rule that the transactions will not result in the acceleration of payments of estate tax under § 6166(g). |
| 200321005(PDF, 39K) |
5/23/2003 |
| Requested ruling that its income is excludable from gross income for federal income tax purposes under § 115(1) of the Internal Revenue Code. |
| 200321004(PDF, 35K) |
5/23/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election to be treated as a corporation for federal tax purposes, and relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200321003(PDF, 24K) |
5/23/2003 |
| Requested ruling under § 301.9100-3(a) of the Procedure and Administration Regulations to file an election for Company to be treated as a partnership for federal tax purposes. |
| 200321002(PDF, 61K) |
5/23/2003 |
| Requested ruling concerning the proposed deferred compensation plan under which Employer intends to provide benefits under § 457(b) and 457(f) of the Internal Revenue Code of 1986 and a related trust. |
| 200321001(PDF, 25K) |
5/23/2003 |
| Requested ruling under § 301.9100-3(a) of the Procedure and Administration Regulations to file an election for Company to be treated as a partnership for federal tax purposes. |
| 200320028(PDF, 1.2M) |
8/19/2003 |
| Requested ruling concerning whether certain plans qualify as church plans under § 414(e) of the Internal Revenue Code. |
| 200320027(PDF, 591K) |
2/20/2003 |
| Requested ruling that borrowings by a Fund under the Line of Credit for the purpose of facilitating redemptions of Units do not give rise to unrelated debt financed income or create any "acquisition indebtedness" within the meaning of § 514 of the Internal Revenue Code. |
| 200320026(PDF, 640K) |
2/20/2003 |
| Requested ruling concerning the proper tax treatment, under § 511-514 of the Internal Revenue Code of the proposed transaction. |
| 200320025(PDF, 39K) |
5/16/2003 |
| Requested ruling under § 1362(f) of the Internal Revenue Code. |
| 200320024(PDF, 46K) |
5/16/2003 |
| Requested ruling that Fund A and Fund B will be treated as Qualified Settlement Funds (QSF) under § 1.468B-1 of the Income Tax Regulations and that the income of Fund A and Fund B is excludible from gross income under § 115(1) of the Internal Revenue Code. |
| 200320023(PDF, 41K) |
5/16/2003 |
| Requested ruling is that the performance of certain cleaning services by property-owning entities in which Trust has an ownership interest will not cause the rental income generated by the properties at which the services are performed to be treated as other than “rents from real property” under § 856(d) of the Internal Revenue Code. |
| 200320022(PDF, 36K) |
5/16/2003 |
| Requested rulings on the federal income tax consequences of a proposed transaction. |
| 200320021(PDF, 29K) |
5/16/2003 |
| Requested 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. |
| 200320020(PDF, 42K) |
5/16/2003 |
| Requested waiver pursuant to § 7702(f)(8) of the Internal Revenue Code for Number 1 insurance contracts Issued by Taxpayer that failed to meet the requirements of § 7702(a). |
| 200320019(PDF, 84K) |
5/16/2003 |
| Requested ruling concerning whether the transfer of an intertie by Generator to Utility A is a non-shareholder contribution to capital excludable from Taxpayer A’s income under § 118(a) of the Internal Revenue Code. |
| 200320018(PDF, 44K) |
5/16/2003 |
| Requested ruling on behalf of Company that the ownership and operation of RV Parks by TRS will not cause TRS to be a corporation which directly or indirectly operates or manages a lodging facility within the meaning of § 856(l)(3)(A) of the Code. |
| 200320017(PDF, 22K) |
5/16/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200320016(PDF, 51K) |
5/16/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to allocate Decedent’s and W’s GST exemption to transfers to Trust. |
| 200320015(PDF, 50K) |
5/16/2003 |
| Requested rulings regarding the effect of the proposed judicial reformation of the trust instrument for federal estate tax purposes. |
| 200320014(PDF, 40K) |
5/16/2003 |
| Requested ruling, under § 301.9100-3 of the Procedure and Administration Regulations, that Taxpayer be granted an extension of time to elect to be treated as an association taxable as a corporation for federal tax purposes under § 301.7701-3(c). |
| 200320013(PDF, 81K) |
5/16/2003 |
| Requested rulings on certain federal income tax consequences of a proposed transaction on behalf of the above-referenced taxpayer. |
| 200320012(PDF, 35K) |
5/16/2003 |
| Requested extension of time under Treasury Regulation § 301.9100-3 to file the agreement provided under § 1.1503-2(g)(2)(i), and to file the annual certification provided under § 1.1503-2(g)(2)(vi)(B) in accordance with the schedule set forth in Exhibit A, which is attached and is made a part of this ruling letter. |
| 200320011(PDF, 33K) |
5/16/2003 |
| Requested ruling on the generation-skipping transfer tax consequences of a proposed reformation of Trust. |
| 200320010(PDF, 56K) |
5/16/2003 |
| Requested 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 1's and Taxpayer 2’s generation-skipping transfer tax exemptions to certain transfers to an irrevocable trust. |
| 200320009(PDF, 50K) |
5/16/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to allocate Decedent’s and W’s GST exemption to transfers to Trust. |
| 200320008(PDF, 28K) |
5/16/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200320007(PDF, 26K) |
5/16/2003 |
| Requested ruling concerning whether service-connected disability benefits paid to disabled participants in Plan A, Plan B, Plan C, and Plan D are excludable from the gross income of the recipients under § 104(a)(1) of the Internal Revenue Code. |
| 200320006(PDF, 35K) |
5/16/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of the Generation-Skipping Transfer exemption. |
| 200320005(PDF, 24K) |
5/16/2003 |
| Requested ruling that X is treated as a trust for federal income tax purposes under § 301.7701-4 of the Procedure and Administration Regulations. |
| 200320004(PDF, 33K) |
5/16/2003 |
| Requesting that X be given an extension of time in which to elect to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200320003(PDF, 25K) |
5/16/2003 |
| Requested extension of time under § 301.9100-1 and § 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as a corporation for federal tax purposes under § 301.7701-3(c). |
| 200320002(PDF, 25K) |
5/16/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200320001(PDF, 55K) |
5/16/2003 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
