| 200329049(PDF, 507K) |
4/21/2003 |
| Request for a ruling that for purposes of the minimum investment return calculation under § 4942(e) of the Internal Revenue Code, the Foundation's assets do not include the value of collateral that is received in connection with the Foundation's securities lending program. |
| 200329048(PDF, 588K) |
4/23/2003 |
| Request for letter rulings: (1) That Trust T is a "see-through" trust as that concept exists under the "Final" Regulations promulgated under § 401(a)(9) of the Code. (2) That IRA X may be subdivided into four sub-IRAs such that each sub-IRA will be created and held, individually, by a separate beneficiary of Trust T in the name of Taxpayer A (Deceased) for the benefit of such beneficiary and with minimum required distributions under § 401 (a)(9) of the Code for each sub-IRA being determined on the basis of the age of the oldest beneficiary, Taxpayer B. |
| 200329047(PDF, 477K) |
4/23/2003 |
| Request relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200329046(PDF, 725K) |
4/23/2003 |
| Request for a private letter ruling, concerning the applicability of § 415(m) of the Internal Revenue Code to an excess plan and the tax consequences of certain related transactions. |
| 200329045(PDF, 95K) |
7/18/2003 |
| Requesting rulings on behalf of a proposed entity to be established by court order to resolve or satisfy certain legal claims. |
| 200329044(PDF, 61K) |
7/18/2003 |
| Requesting relief under §1362(b)(5) of the Internal Revenue Code. |
| 200329043(PDF, 153K) |
7/18/2003 |
| Requesting rulings as to the federal income tax consequences of certain proposed transactions. |
| 200329042(PDF, 92K) |
7/18/2003 |
| Requested an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations for K to file the required Form 970, Application to use LIFO Inventory Method which is to be effective for the taxable year ended B. |
| 200329041(PDF, 83K) |
7/18/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to allocate Taxpayer’s generation-skipping transfer tax exemption to a transfer to an irrevocable trust. |
| 200329040(PDF, 44K) |
7/18/2003 |
| Requested a waiver of certain errors under § 7702(f)(8) of the Internal Revenue Code and that certain life insurance contracts will be treated as life insurance contracts for federal income tax purposes. Further, you have requested that the proposed amendment to bring the Contracts into compliance § 72, 264, 7702 and 7702A, not require retesting or the beginning of a new test period under § 264(d)(1), 7702(f)(7)(B)-(E), and 7702A(c), and not be treated as an exchange for Federal tax purposes. |
| 200329039(PDF, 45K) |
7/18/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to allocate Taxpayer’s generation-skipping transfer tax exemption to a transfer to an irrevocable trust. |
| 200329038(PDF, 27K) |
7/18/2003 |
| Request an extension of time under Treasury Regulation § 301.9100-3 to elect the provisions of Revenue Procedure 2002-23, 2002-15 IRB. 744. |
| 200329037(PDF, 30K) |
7/18/2003 |
| Requesting a ruling, under § 301.9100-3 of the Procedure and Administration Regulations, that A be granted an extension of time to elect to be disregarded as separate from its owner for federal tax purposes under § 301.7701-3(c). |
| 200329036(PDF, 31K) |
7/18/2003 |
| Requesting a ruling, under § 301.9100-3 of the Procedure and Administration Regulations, that A be granted an extension of time to elect to be disregarded as separate from its owner for federal tax purposes under § 301.7701-3(c). |
| 200329035(PDF, 37K) |
7/18/2003 |
| Requesting a ruling that the proposed Amendment and Restatement of the Declaration of Trust of Fund and the transfer of X’s remainder interests in Fund to Y do not affect the Fund’s qualification as a pooled income fund within the meaning of § 642(c)(5) of the Internal Revenue Code or the applicability of the prior private letter rulings issued by the Service to Fund. X also requests a ruling that after the adoption of the Amendment and Restatement of the Declaration of Trust the Fund will be treated as continuing in operation and will not be treated as a fund subject to § 1.642(c)-6(e)(4) of the Income Tax Regulations. |
| 200329034(PDF, 24K) |
7/18/2003 |
| Requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 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. |
| 200329033(PDF, 24K) |
7/18/2003 |
| Requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 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. |
| 200329032(PDF, 31K) |
7/18/2003 |
| Requesting a ruling under § 216 of the Internal Revenue Code. |
| 200329031(PDF, 74K) |
7/18/2003 |
| Requesting a ruling that the proposed Amendment and Restatement of the Declaration of Trust of Fund and the transfer of X’s remainder interests in Fund to Y do not affect the Fund’s qualification as a pooled income fund within the meaning of § 642(c)(5) of the Internal Revenue Code or the applicability of the prior private letter rulings issued by the Service to Fund. Y also requests a ruling that after the adoption of the Amendment and Restatement of the Declaration of Trust the Fund will be treated as continuing in operation and will not be treated as a fund subject to § 1.642(c)-6(e)(4) of the Income Tax Regulations. |
| 200329030(PDF, 72K) |
7/18/2003 |
| Requesting relief under § 301.7701-3(c)(1)(iv) and 301.9100-3 of the Procedure and Administration Regulations for Y to elect to change its federal tax classification effective Date 4. |
| 200329029(PDF, 59K) |
7/18/2003 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200329028(PDF, 64K) |
7/18/2003 |
| Request for rulings regarding certain federal income tax consequences of a proposed transaction. |
| 200329027(PDF, 70K) |
7/18/2003 |
| Request for a private letter ruling requesting permission to revoke an election out of the installment method for the sale of certain stock under § 453 of the Internal Revenue Code and § 15a.453-1(d)(4) of the Temporary Income Tax Regulations. |
| 200329026(PDF, 70K) |
7/18/2003 |
| Request for a private letter ruling requesting permission to revoke an election out of the installment method for the sale of certain stock under § 453 of the Internal Revenue Code and § 15a.453-1(d)(4) of the Temporary Income Tax Regulations. |
| 200329025(PDF, 29K) |
7/18/2003 |
| Requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that you 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. |
| 200329024(PDF, 27K) |
7/18/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200329023(PDF, 65K) |
7/18/2003 |
| Requesting a ruling under § 305 of the Internal Revenue Code. |
| 200329022(PDF, 73K) |
7/18/2003 |
| Requesting a ruling under § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200329021(PDF, 111K) |
7/18/2003 |
| Requesting a private letter ruling under §1031 of the Internal Revenue Code that no gain or loss will be recognized upon the conveyance of RQ and the receipt of RP. |
| 200329020(PDF, 33K) |
7/18/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Lossco is requesting an extension to file a "closing-of-the-books election" pursuant to § 1.382-6(b) of the Income Tax Regulations, with respect to a transaction that occurred on Date 1. |
| 200329019(PDF, 146K) |
7/18/2003 |
| Requesting rulings on several Issues: arising from the establishment, funding and potential termination of Trust under § 646 of the Internal Revenue Code and other provisions. |
| 200329018(PDF, 133K) |
7/18/2003 |
| Requesting rulings on several Issues: arising from the establishment, funding and potential termination of Trust under § 646 of the Internal Revenue Code and other provisions. |
| 200329017(PDF, 75K) |
7/18/2003 |
| Fund requests that its election under § 855(a) of the Internal Revenue Code to treat dividends distributed after the close of a taxable year as having been paid during that taxable year be considered timely filed pursuant to § 301.9100-3 of the Procedure and Administration Regulations. |
| 200329016(PDF, 75K) |
7/18/2003 |
| Seeking a ruling on the classification of Trust under § 301.7701-4(d) of the Procedure and Administration Regulations. |
| 200329015(PDF, 63K) |
7/18/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200329014(PDF, 72K) |
7/18/2003 |
| Requesting rulings on behalf of Taxpayer concerning the proper Federal tax treatment of a medical reimbursement plan and a qualified parking payment plan. |
| 200329013(PDF, 64K) |
7/18/2003 |
| Requesting a ruling on behalf of X under § 1362(b)(5) of the Internal Revenue Code. |
| 200329012(PDF, 72K) |
7/18/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200329011(PDF, 118K) |
7/18/2003 |
| Request for rulings on certain federal income tax consequences under § 1361 and 1374 of the Code with regard to your Date 5 conversion from a “C corporation” pursuant to § 1361(a)(2) to an “S corporation” pursuant to § 1361(a)(1). |
| 200329010(PDF, 65K) |
7/18/2003 |
| 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. |
| 200329009(PDF, 61K) |
7/18/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200329008(PDF, 65K) |
7/18/2003 |
| 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. |
| 200329007(PDF, 64K) |
7/18/2003 |
| 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. |
| 200329006(PDF, 65K) |
7/18/2003 |
| 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. |
| 200329005(PDF, 67K) |
7/18/2003 |
| Requesting on behalf of Funds A through E (Funds) extensions of time to file elections under § 855(a) of the Internal Revenue Code (§ 855 elections). |
| 200329004(PDF, 77K) |
7/18/2003 |
| Request on behalf of Issuer and for the following rulings with respect to the Bonds for the Facility payments under the Agreements that are attributable to Issuer’s ordinary and necessary business expenses may be disregarded for purposes of applying § 1.141-7(f)(1) of the Income Tax Regulations. |
| 200329003(PDF, 85K) |
7/18/2003 |
| Requested ruling on behalf of H in your letter of December 3, 2002, concerning a proposed lump-sum payment to be made to W in satisfaction of all spousal support obligations of H. |
| 200329002(PDF, 66K) |
7/18/2003 |
| Requesting on behalf of Company an extension of time under § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations for Company to elect to be treated as a disregarded entity under § 301.7701-3(c). |
| 200329001(PDF, 73K) |
7/18/2003 |
| Requested ruling concerning Capital Interest, Rev. Proc. 93-27, 1993-2 C.B. 343. |
| 200328050(PDF, 191K) |
4/18/2003 |
| Constitutes notice that with respect to the above-named defined benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ended December 31,2001. |
| 200328049(PDF, 311K) |
4/17/2003 |
| Requested rulings on a contingent set-aside under § 53.4942(a)-3(b)(9) of the Foundation and Similar Excise Taxes Regulations. |
| 200328048(PDF, 435K) |
4/17/2003 |
| Requesting rulings on your behalf regarding the federal income tax consequences of the transfer from B to C of certain assets, and the subsequent sale or exchange of those assets, under § 511 of the Internal Revenue Code. |
| 200328047(PDF, 114K) |
4/17/2003 |
| Requested rulings with respect to the above-referenced defined benefit pension plan pursuant to Rev. Proc. 90-49, 1990-2 C.B. 620, for the plan year commencing January 1,2002. |
| 200328046(PDF, 437K) |
4/17/2003 |
| Requesting rulings on your behalf regarding the federal income tax consequences of the transfer from B to C of certain assets, and the subsequent sale or exchange of those assets, under § 511 of the Internal Revenue Code. |
| 200328045(PDF, 436K) |
4/17/2003 |
| Requesting rulings on your behalf regarding the federal income tax consequences of the transfer from B to C of certain assets, and the subsequent sale or exchange of those assets, under § 511 of the Internal Revenue Code. |
| 200328044(PDF, 118K) |
4/17/2003 |
| Requested rulings with respect to the above-referenced defined benefit pension plan pursuant to Rev. Proc. 90-49, 1990-2 C.B. 620, for the plan year commencing January 1,2002. |
| 200328043(PDF, 913K) |
4/17/2003 |
| Requested ruling concerning the pick up of certain employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200328042(PDF, 427K) |
4/16/2003 |
| Requested ruling regarding the federal income tax consequences of the transfer from B to C of certain assets, and the subsequent sale or exchange of those assets, under § 511 of the Internal Revenue Code. |
| 200328041(PDF, 391K) |
4/15/2003 |
| This letter constitutes notice that a conditional waiver of a portion of the minimum funding standard has been granted for the above-named pension plan for the plan year beginning January 1, 2003. |
| 200328040(PDF, 352K) |
4/15/2003 |
| This letter constitutes notice that a conditional waiver of the minimum funding standard has been granted for the above-named pension plan for the plan year beginning January 1, 2003. |
| 200328039(PDF, 354K) |
4/15/2003 |
| This letter constitutes notice that a conditional waiver of the minimum funding standard has been granted for the above-named pension plan for the plan year beginning January 1, 2003. |
| 200328038(PDF, 136K) |
4/16/2003 |
| Requested ruling with respect to the above-referenced defined benefit pension plan pursuant to Rev. Proc. 90-49, 1990-2 C.B. 620, for the plan year commencing. |
| 200328037(PDF, 289K) |
4/14/2003 |
| This letter constitutes notice that a conditional waiver of the minimum funding standard has been granted for the above-named pension plan for the plan year beginning January 1, 2002. |
| 200328036(PDF, 66K) |
7/11/2003 |
| Requested ruling concerning the federal tax treatment under § 104(a)(1) of the Internal Revenue Code of benefits received by police officers and firefighters from the Plans that you maintain. |
| 200328035(PDF, 78K) |
7/11/2003 |
| Requested ruling regarding the income tax consequences under § 1001 of the Internal Revenue Code of the proposed partition of the Jointly-Owned Property (JOP) into separate parcels. You have requested a ruling that the partition does not constitute a sale, exchange, or other disposition that would cause any of the taxpayers, A, B, C, or T, to recognize any gain or loss under § 1001. |
| 200328034(PDF, 78K) |
7/11/2003 |
| Requested ruling regarding the income tax consequences under § 1001 of the Internal Revenue Code of the proposed partition of the Jointly-Owned Property (JOP) into separate parcels. You have requested a ruling that the partition does not constitute a sale, exchange, or other disposition that would cause any of the taxpayers, A, B, C, or T, to recognize any gain or loss under § 1001. |
| 200328033(PDF, 83K) |
7/11/2003 |
| Requesting a ruling that the receipt of a certain tax indemnity payment pursuant to a litigation settlement with the taxpayer’s former employer is not includible in the taxpayer’s gross income. |
| 200328032(PDF, 115K) |
7/11/2003 |
| Requesting rulings under § 61, 643(f), 661, 1001, 1015, 1223 and 2601 of the Internal Revenue Code. |
| 200328031(PDF, 65K) |
7/11/2003 |
| 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. |
| 200328030(PDF, 100K) |
7/11/2003 |
| Requesting a ruling concerning the federal income, gift, and estate tax consequences of the creation of a proposed charitable lead unitrust. |
| 200328029(PDF, 16K) |
7/11/2003 |
| *PULLED* |
| 200328028(PDF, 64K) |
7/11/2003 |
| 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. |
| 200328027(PDF, 98K) |
7/11/2003 |
| Requested a waiver of certain errors under § 7702(f)(8) of the Internal Revenue Code such that various life insurance contracts (Contracts) will be treated as life insurance contracts for federal tax purposes. |
| 200328026(PDF, 89K) |
7/11/2003 |
| Requested a ruling concerning the generation-skipping transfer tax and gift tax consequences of the proposed judicial construction of a trust agreement that is exempt from the application of generation-skipping transfer tax imposed under Internal Revenue Code § 2601. |
| 200328025(PDF, 66K) |
7/11/2003 |
| Requesting a ruling that X's rental income from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200328024(PDF, 63K) |
7/11/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200328023(PDF, 69K) |
7/11/2003 |
| Request for extension of time to file application for certification of historic status. Requesting an 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. |
| 200328022(PDF, 59K) |
7/11/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200328021(PDF, 74K) |
7/11/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of generation-skipping transfer tax exemption. |
| 200328020(PDF, 65K) |
7/11/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200328019(PDF, 79K) |
7/11/2003 |
| An extension of time was requested 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 a transfer to an irrevocable life insurance trust, Trust, created by Decedent. |
| 200328018(PDF, 72K) |
7/11/2003 |
| 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 treated as a partnership for federal income tax purposes. |
| 200328017(PDF, 61K) |
7/11/2003 |
| Requested relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200328016(PDF, 83K) |
7/11/2003 |
| 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 timely allocations of generation-skipping transfer exemption with respect to transfers made by Grantor to an irrevocable trust. |
| 200328015(PDF, 98K) |
7/11/2003 |
| Requesting rulings regarding the federal gift and income tax consequences of a modification of a trust and division of trust assets as described below. |
| 200328014(PDF, 76K) |
7/11/2003 |
| 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 under § 754 of the Internal Revenue Code for the period ending d1 |
| 200328013(PDF, 68K) |
7/11/2003 |
| Requesting that the Service grant Y an extension of time pursuant to § 301.9100 of the Procedure and Administration Regulations to file a Form 8832, Entity Classification Election, to be treated as a disregarded entity effective D1 |
| 200328012(PDF, 77K) |
7/11/2003 |
| Requesting an extension of time under § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an election under § 2057(b)(1)(B) of the Internal Revenue Code. |
| 200328011(PDF, 68K) |
7/11/2003 |
| Requesting that the Service grant Y an extension of time pursuant to § 301.9100 of the Procedure and Administration Regulations to file a Form 8832, Entity Classification Election, to be treated as a disregarded entity effective D1 |
| 200328010(PDF, 62K) |
7/11/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200328009(PDF, 61K) |
7/11/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200328008(PDF, 61K) |
7/11/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200328007(PDF, 62K) |
7/11/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200328006(PDF, 60K) |
7/11/2003 |
| Issue: May Actuarial Guideline 33 (AG33) be used in computing Taxpayer’s CARVM tax reserves for annuity contracts that were issued before the date on which the guideline took effect, or the date of adoption by the National Association of Insurance Commissioners (NAIC), whichever is later, under § 807(d)(2) of the Internal Revenue Code. |
| 200328005(PDF, 63K) |
7/11/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200328004(PDF, 62K) |
7/11/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200328003(PDF, 95K) |
7/11/2003 |
| Request dated June 6, 2000, for a determination that Trusts A through C, domestic trusts, Corps A through C, domestic corporations, Partnerships A and C, domestic partnerships, and Individuals A through I, U.S. citizens or residents, (hereinafter collectively referred to as “Taxpayers) are eligible to make retroactive elections to treat certain investments in passive foreign investment companies (PFICs) as qualified electing funds (QEFs) pursuant to Treasury Regulation § 1.1295- |
| 200328002(PDF, 89K) |
7/11/2003 |
| This letter refers to a Form 3115, Application for Change in Accounting Method, filed by Parent on behalf of Sub 1, Sub 2, Sub 3, Sub 4, Sub 5 and Sub 6 (collectively the Subsidiaries) requesting permission to change their methods of accounting related to the production of delivery systems and the manufacture of packaging for the taxable year beginning Date 1 (year of change). |
| 200328001(PDF, 158K) |
7/11/2003 |
| Issues: (1) Can an examining agent change Taxpayer’s method of determining the current-year cost of items making up its inventory pool under the last-in, first-out (LIFO) method of accounting when Taxpayer received the Commissioner’s consent to use the ”earliest acquisition” method but instead used a “dual index” method? (2) Should the National Office revoke a letter ruling that granted Taxpayer permission to select month 1 as an appropriate representative month for purposes of the Inventory Price Index Computation (IPIC) method under Treasury Regulation § 1.472-8(e)(3), and if the National Office revokes its letter ruling, what month would be most appropriate to Taxpayer’s method of determining current-year cost? (3) Should Taxpayer be granted relief under § 7805(b) of the Internal Revenue Code if the National Office revokes the letter ruling that granted it permission to select month 1 as an appropriate representative month? (4) Is Taxpayer permitted to use a dual index method to determine the current-year cost of items making up its inventory pool when it uses the IPIC method?" |
| 200327068(PDF, 861K) |
4/10/2003 |
| Requested ruling concerning the pick up of certain employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200327067(PDF, 756K) |
4/9/2003 |
| Requesting a series of rulings on your behalf regarding the tax consequences associated with a proposed joint venture for the operation of a neonatal intensive care unit. |
| 200327066(PDF, 845K) |
4/9/2003 |
| Request rulings regarding the tax consequences of a proposed transfer of assets held in a retired health reserve to a voluntary employees' beneficiary association (VEBA). |
| 200327065(PDF, 799K) |
4/9/2003 |
| Requesting a series of rulings on your behalf regarding the tax consequences associated with a proposed joint venture for the operation of a neonatal intensive care unit. |
| 200327064(PDF, 394K) |
4/9/2003 |
| Request of a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200327063(PDF, 840K) |
4/9/2003 |
| Request rulings regarding the tax consequences of a proposed transfer of assets held in a retired health reserve to a voluntary employees' beneficiary association (VEBA). |
| 200327062(PDF, 376K) |
4/9/2003 |
| Requested ruling of approval of a proposed set-aside of funds, to be treated as qualifying distributions under § 4942(g)(2) of the Internal Revenue Code, for its taxable year ending December 31,2001. |
| 200327061(PDF, 477K) |
4/8/2003 |
| Requested ruling concerning the federal income tax treatment of mandatory employee contributions that will be picked up by County X under § 414(h)(2) of the Code. |
| 200327060(PDF, 156K) |
4/7/2003 |
| Requesting advance approval of your grant-making procedures under § 4945(g) of the Internal Revenue Code. |
| 200327059(PDF, 521K) |
4/10/2003 |
| Requested ruling under 9 401(a)(9) of the Internal Revenue Code. |
| 200327058(PDF, 87K) |
7/3/2003 |
| Requesting rulings under §216 and §1032 of the Internal Revenue Code. |
| 200327057(PDF, 153K) |
7/3/2003 |
| Request for rulings on certain federal income tax consequences of a proposed series of transactions. |
| 200327056(PDF, 66K) |
7/3/2003 |
| On behalf of Fund by Company, requesting an extension of time pursuant to § 301.9100-1(a) of the Procedure and Administration Regulations for Fund to make an election under § 855(a) of the Internal Revenue Code for Year 1. |
| 200327055(PDF, 62K) |
7/3/2003 |
| Requesting permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200327054(PDF, 93K) |
7/3/2003 |
| Requesting rulings on the Federal income tax consequences of a proposed transaction. |
| 200327053(PDF, 148K) |
7/3/2003 |
| Issue: Whether § 1341 applies to payments for retired employees’ medical expenses. |
| 200327052(PDF, 123K) |
7/3/2003 |
| Requesting a ruling that certain reserves held by certain foreign subsidiaries for life insurance and annuity contracts required to be set forth on the financial statements and filed with the life insurance regulators of Country A are an appropriate means of measuring income within the meaning of § 954(i)(4)(B)(ii) of the Internal Revenue Code of 1986, as amended. |
| 200327051(PDF, 78K) |
7/3/2003 |
| Requesting rulings on the Federal income tax consequences of a proposed transaction. |
| 200327050(PDF, 74K) |
7/3/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser 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, on Date B. |
| 200327049(PDF, 70K) |
7/3/2003 |
| Request that we supplement our letter ruling dated March 22, 2001 (PLR-112614-00) (the “Prior Letter Ruling). |
| 200327048(PDF, 97K) |
7/3/2003 |
| Requesting ruling regarding the qualification of certain income as rents from real property for purposes of § 856(d) of the Internal Revenue Code. |
| 200327047(PDF, 139K) |
7/3/2003 |
| Requested a ruling and closing agreement that premiums received by Taxpayer on policies of insurance or reinsurance of United States risks are exempt from the insurance excise tax imposed by § 4371 of the Internal Revenue Code pursuant to the Income Tax Convention between the United States and the Federal Republic of Germany (the “Convention). |
| 200327046(PDF, 61K) |
7/3/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200327045(PDF, 62K) |
7/3/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200327044(PDF, 60K) |
7/3/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200327043(PDF, 67K) |
7/3/2003 |
| Requested, on behalf of Decedent’s Estate, an extension of time under § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an alternate valuation election under § 2032 of the Internal Revenue Code. |
| 200327042(PDF, 105K) |
7/3/2003 |
| Request for a review of the Commission B's jurisdictional schedule of ruling amounts contained in the Prior Schedule, pursuant to § 1.468A-3(i)(1) of the Income Tax Regulations. |
| 200327041(PDF, 80K) |
7/31/2003 |
| Taxpayer filed the Form 3115, Application for Change in Accounting Method, under Rev. Proc. 97-27, 1997-1 C. B. 680, to request permission to change its method of computing depreciation for certain residential rental property. |
| 200327040(PDF, 81K) |
7/3/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to allocate your generation-skipping transfer tax exemptions to certain transfers to an irrevocable trust. |
| 200327039(PDF, 231K) |
7/3/2003 |
| Requesting rulings on the proper federal income tax treatment of certain exchanges of personal property under Taxpayer’s Like-Kind Exchange Program (LKE Program). |
| 200327038(PDF, 76K) |
7/3/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser and Seller are requesting an extension to file a “§ 338(h)(10) election” under § 338(g) and 338(h)(10) of the Internal Revenue Code and § 1.338(h)(10)-1T(c) of the Income Tax Regulations with respect to Purchaser’s acquisition of the stock of Target, on Date A. |
| 200327037(PDF, 104K) |
7/3/2003 |
| Requesting a waiver under § 7702(f)(8) of the Internal Revenue Code for various life insurance contracts that inadvertently failed to meet the requirements of § 7702. |
| 200327036(PDF, 63K) |
7/3/2003 |
| Request that Taxpayer be granted an extension of time under Treasury Regulation § 301.9100-3 to file the following annual certifications as required under § 1.1503-2(g)(2)(vi) for the tax years indicated: (1) an annual certification for TYE 2 with respect to the dual consolidated losses for TYE 1 attributable to Taxpayer’s X interest in Entity A; (2) an annual certification for TYE 3 with respect to the dual consolidated losses for TYE 1 and TYE 2 attributable to Taxpayer’s X interest in Entity A; and (3) an annual certification for TYE 3 with respect to the dual consolidated losses for TYE 2 attributable to Taxpayer’s Y interest in Entity B. |
| 200327035(PDF, 75K) |
7/3/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser and Seller are requesting an extension to file a “§ 338(h)(10) election” under § 338(g) and 338(h)(10) of the Internal Revenue Code and § 1.338(h)(10)-1(c) of the Income Tax Regulations with respect to Purchaser’s acquisition of the stock of Target, on Date A. |
| 200327034(PDF, 77K) |
7/3/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser 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(d) of the Income Tax Regulations with respect to Purchaser’s acquisition of the stock of Target, on Date B. |
| 200327033(PDF, 61K) |
7/3/2003 |
| Requesting a ruling that Corporation may determine the credit for increasing research activities (research credit) under the standard method of § 41(a) of the Internal Revenue Code for Corporation’s taxable year ending on a and all subsequent taxable years. |
| 200327032(PDF, 61K) |
7/3/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200327031(PDF, 60K) |
7/3/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200327030(PDF, 59K) |
7/3/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200327029(PDF, 77K) |
7/3/2003 |
| Requesting a ruling that X's rental income from its commercial rental properties and X’s interest income from its lending business is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200327028(PDF, 72K) |
7/3/2003 |
| Requested a ruling that each Fund be granted an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an election under § 855(a) of the Internal Revenue Code for Fund’s tax year ended Date 1. |
| 200327027(PDF, 87K) |
7/3/2003 |
| Requesting rulings under Internal Revenue Code § 368 and 355. |
| 200327026(PDF, 89K) |
7/3/2003 |
| Determination whether the Taxpayer has sufficiently satisfied the requirements under Internal Revenue Code § 1295 to treat certain investments in passive foreign investment companies (PFICs) as qualified electing funds (QEFs) based on the doctrine of substantial compliance. |
| 200327025(PDF, 59K) |
7/3/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200327024(PDF, 84K) |
7/3/2003 |
| Requesting a ruling that the income of Association is excludable from gross income under § 115(1) of the Internal Revenue Code. |
| 200327023(PDF, 67K) |
7/3/2003 |
| Requesting rulings under § 41 of the Internal Revenue Code. |
| 200327022(PDF, 58K) |
7/3/2003 |
| Requesting permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200327021(PDF, 60K) |
7/3/2003 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200327020(PDF, 87K) |
7/3/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200327019(PDF, 111K) |
7/3/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200327018(PDF, 80K) |
7/3/2003 |
| Requested rulings concerning the federal income tax consequences of a proposed transaction. |
| 200327017(PDF, 41K) |
7/3/2003 |
| Submitted on behalf of A by A's authorized representatives, for an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations. Specifically, A has requested an extension of time to file a Form 970, Application To Use LIFO Inventory Method, for the year ended Date 1. |
| 200327016(PDF, 78K) |
7/3/2003 |
| This letter revokes and replaces private letter ruling 200242025 (PLR-114698-02) issued on July 17, 2002, to Daughter, as trustee of the Estate. A private letter ruling found to be in error or not in accord with the current views of the Service may be revoked or modified. Rev. Proc. 2003-1, § 12.04. |
| 200327015(PDF, 61K) |
7/3/2003 |
| Requesting a ruling on behalf of Corporation under § 1362(b)(5) of the Internal Revenue Code. |
| 200327014(PDF, 61K) |
7/3/2003 |
| Requesting permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200327013(PDF, 66K) |
7/3/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200327012(PDF, 61K) |
7/3/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200327011(PDF, 61K) |
7/3/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200327010(PDF, 61K) |
7/3/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200327009(PDF, 61K) |
7/3/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200327008(PDF, 56K) |
7/3/2003 |
| Requested ruling concerning whether Taxpayer qualifies for the excise tax exemptions allowed to state and local governments under § 4041(g)(2), 4221(a)(4), 4253(i), and 4483(a) of the Internal Revenue Code. |
| 200327007(PDF, 91K) |
7/3/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of the generation-skipping transfer tax exemption to a transfer to a trust. |
| 200327006(PDF, 90K) |
7/3/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of the generation-skipping transfer tax exemption to a transfer to a trust. |
| 200327005(PDF, 81K) |
7/3/2003 |
| 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 a transfer to a trust. |
| 200327004(PDF, 90K) |
7/3/2003 |
| Requested rulings under § 1362(d)(3) and 1375(a) of the Internal Revenue Code. |
| 200327003(PDF, 96K) |
7/3/2003 |
| Requesting on behalf of Company a ruling that an undivided fractional interest in rental real property is not an interest in a business entity under § 301.7701-2(a) of the Procedure and Administration Regulations for purposes of qualification of the undivided fractional interest as eligible replacement property under § 1031(a) of the Internal Revenue Code. |
| 200327002(PDF, 74K) |
7/3/2003 |
| Issue: Whether payments received by a U.S. resident alien, pursuant to interests in three foreign business enterprises created in her favor under foreign law by her father, should be included in her gross income under Internal Revenue Code § 61. |
| 200327001(PDF, 73K) |
7/3/2003 |
| Requesting a second 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 a second 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 A. |
| 200326045(PDF, 1.1M) |
4/2/2003 |
| Requested ruling with respect to the applicability of § 414(e) of the Internal Revenue Code to Plan X and Plan Y. |
| 200326044(PDF, 190K) |
4/2/2003 |
| Constitutes notice that with respect to the Money Purchase Plan, a conditional waiver of the 100 percent excise tax under § 4971 (b) of the Internal Revenue Code has been granted for the excise tax that would otherwise apply with respect to the plan year beginning January 1, 2001. |
| 200326043(PDF, 874K) |
4/1/2003 |
| Request rulings under § 501 (c)(3), 509 and 511 through 513 of the Internal Revenue Code. In addition, A, F, and P requested three bond rulings which will be answered by Tax Exempt Bonds under separate cover. |
| 200326042(PDF, 897K) |
4/1/2003 |
| Request rulings under § 501 (c)(3), 509 and 511 through 513 of the Internal Revenue Code. In addition, A, F, and P requested three bond rulings which will be answered by Tax Exempt Bonds under separate cover. |
| 200326041(PDF, 859K) |
4/1/2003 |
| Request rulings under § 501 (c)(3), 509 and 511 through 513 of the Internal Revenue Code. In addition, A, F, and P requested three bond rulings which will be answered by Tax Exempt Bonds under separate cover. |
| 200326040(PDF, 1.5M) |
3/31/2003 |
| Requested rulings under § 4941 and 664 of the Internal Revenue Code with respect to the formation of, and transactions involving, a split interest trust described in § 4947(a)(2) as more fully set forth below. |
| 200326039(PDF, 1.5M) |
3/31/2003 |
| Requested rulings under § 4941 and 664 of the Internal Revenue Code with respect to the formation of, and transactions involving, a split interest trust described in § 4947(a)(2) as more fully set forth below. |
| 200326038(PDF, 1.1M) |
4/2/2003 |
| Requested ruling with respect to an arrangement under § 403(b)(9) of the Internal Revenue Code |
| 200326037(PDF, 509K) |
4/1/2003 |
| Requested ruling concerning the federal income tax treatment of certain contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200326036(PDF, 296K) |
4/2/2003 |
| Request for a ruling as to whether Plan X is a governmental plan within the meaning of § 414(d) of the Internal Revenue Code. |
| 200326035(PDF, 1.4M) |
4/4/2003 |
| Request for rulings under § 511 and 501 (c)(3) of the Internal Revenue Code. |
| 200326034(PDF, 120K) |
6/27/2003 |
| Issues: (1) Whether Taxpayer’s claimed loss on the disposition of FC is disallowed on the grounds that Taxpayer improperly determined basis in the FC. (2) Whether the Internal Revenue Code § 6662 accuracy-related penalty can be asserted against Taxpayer if the loss is disallowed. |
| 200326033(PDF, 65K) |
6/27/2003 |
| 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. |
| 200326032(PDF, 48K) |
6/27/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200326031(PDF, 93K) |
6/27/2003 |
| Requesting relief under § 301.9100-3 of the Procedure and Administration Regulations to make the consent dividend election under § 565(a) of the Internal Revenue Code. |
| 200326030(PDF, 46K) |
6/27/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of Taxpayer 1's and Taxpayer 2's generation-skipping transfer tax exemptions. |
| 200326029(PDF, 93K) |
6/27/2003 |
| Requested ruling regarding the generation-skipping transfer tax consequences of a proposed modification to a trust. |
| 200326028(PDF, 81K) |
6/27/2003 |
| Requested ruling under § 1362(f) of the Internal Revenue Code. |
| 200326027(PDF, 80K) |
6/27/2003 |
| Requested ruling under § 1362(f) of the Internal Revenue Code. |
| 200326026(PDF, 87K) |
6/27/2003 |
| Requested ruling pursuant to Treasury Regulation § 301.9100-1 and -3 for an extension of time to execute a consent dividend election under Internal Revenue Code § 565 for the year ended Date1. |
| 200326025(PDF, 99K) |
6/27/2003 |
| Requested rulings as to the federal income tax consequences of a proposed transaction. |
| 200326024(PDF, 100K) |
6/27/2003 |
| Requested rulings as to the federal income tax consequences of a proposed transaction. |
| 200326023(PDF, 100K) |
6/27/2003 |
| Requested rulings as to the federal income tax consequences of a proposed transaction. |
| 200326022(PDF, 60K) |
6/27/2003 |
| Requested ruling regarding the late filing of a Form 8716, Election To Have a Tax Year Other Than a Required Tax Year. The taxpayer has requested that its late-filed Form 8716 be considered timely filed under authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200326021(PDF, 71K) |
6/27/2003 |
| 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. |
| 200326020(PDF, 90K) |
6/27/2003 |
| Requested rulings on the federal income tax consequences of a proposed transaction. The ruling request supplements a previous request for rulings dated November 14, 2001, subsequently withdrawn, including additional information that was submitted in letters dated January 17 and March 13, 2002. |
| 200326019(PDF, 104K) |
6/27/2003 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. Taxpayer is requesting this schedule because Commission, in Final Order, decreased the amount of decommissioning costs to be included in cost of service for Plant. Transferor previously received a schedule of ruling amounts pertaining to Plant on A. |
| 200326018(PDF, 66K) |
6/27/2003 |
| 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. |
| 200326017(PDF, 60K) |
6/27/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200326016(PDF, 83K) |
6/27/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200326015(PDF, 99K) |
6/27/2003 |
| Request for rulings that the transactions discussed below will qualify for installment sale treatment under § 453 of the Internal Revenue Code. |
| 200326014(PDF, 67K) |
6/27/2003 |
| Requested ruling on behalf of Taxpayer that rental income earned by Taxpayer at its Commercial Real Estate, Residential Real Estate, and Undeveloped Lots (collectively referred to as Properties) will not be treated as passive investment income under § 1362(d)(3) of the Internal Revenue Code. |
| 200326013(PDF, 82K) |
6/27/2003 |
| Requested an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations for P to file the required Forms 970, Applications to use LIFO Inventory Method, on behalf of its subsidiaries, S1 and S2. |
| 200326012(PDF, 85K) |
6/27/2003 |
| Requested ruling that the income of Corporation is excludable from gross income under § 115(1) of the Internal Revenue Code. |
| 200326011(PDF, 70K) |
6/27/2003 |
| Requested extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200326010(PDF, 68K) |
6/27/2003 |
| Requested extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200326009(PDF, 68K) |
6/27/2003 |
| Requested extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200326008(PDF, 71K) |
6/27/2003 |
| Request for a written determination, dated December 20, 2002, and submitted on behalf of X, Requested extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200326007(PDF, 71K) |
6/27/2003 |
| Requesting that X be given an extension of time to elect to treat Y as a Qualified Subchapter S Subsidiary for its taxable year beginning Date 4 under § 301.9100 of the Procedure and Administration Regulations, as well as relief under § 1362(f) of the Internal Revenue Code for inadvertent termination relief. |
| 200326006(PDF, 25K) |
6/27/2003 |
| Request an 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 an association taxable as a corporation for federal tax purposes under § 301.7701-3(c). |
| 200326005(PDF, 68K) |
6/27/2003 |
| Request for a written determination, dated December 20, 2002, and submitted on behalf of X, Requested extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200326004(PDF, 76K) |
6/27/2003 |
| 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 an irrevocable trust, Trust, created by Decedent. |
| 200326003(PDF, 74K) |
6/27/2003 |
| Requested rulings on certain federal income tax consequences of proposed and completed transactions. |
| 200326002(PDF, 71K) |
6/27/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code. |
| 200326001(PDF, 71K) |
6/27/2003 |
| Requested ruling under § 2601 of the Internal Revenue Code. |
| 200325008(PDF, 405K) |
12/6/2002 |
| Requested ruling 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 (IRA) following the death of the decedent. |
| 200325007(PDF, 746K) |
3/25/2003 |
| Requested ruling concerning the pick up of certain employee contributions to Plan Y under § 414(h)(2) of the lnternal Revenue Code. |
| 200325006(PDF, 130K) |
3/28/2003 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan we have granted a waiver of the minimum funding standard for the plan year ended December 31,2001. |
| 200325005(PDF, 980K) |
3/27/2003 |
| Request for rulings regarding the federal income tax consequences of your proposed activity of investing in foreign financial institutions under the cInternal Revenue Codeumstances described below. |
| 200325004(PDF, 1.2M) |
3/25/2003 |
| Request for rulings concerning the federal tax consequences of your participation in a joint venture that will manage a neonatal intensive care unit (NICU). |
| 200325003(PDF, 1.2M) |
3/25/2003 |
| Request for rulings concerning the federal tax consequences of your participation in a joint venture that will manage a neonatal intensive care unit (NICU). |
| 200325002(PDF, 133K) |
6/20/2003 |
| Issues: (1) Whether annual “rental” payments received by Taxpayer A, who is an individual, for land enrolled in the CRP constitute self-employment income to Taxpayer A that is subject to SECA tax where Taxpayer A was engaged in the trade or business of farming prior to enrolling the land in the CRP and Taxpayer A personally fulfilled her CRP contractual obligations. (2) Whether annual “rental” payments received by Taxpayer B, who is an individual, for newly acquired land, that had been enrolled in the CRP by the land’s previous owner and the enrollment is continued by the Taxpayer B, constitute self-employment income to Taxpayer B subject to SECA tax where Taxpayer B was not engaged in the trade or business of farming prior to acquiring the land but Taxpayer B personally fulfilled his CRP contractual obligations. (3) Whether the annual “rental” payments respectively received by Taxpayer A and Taxpayer B under the CRP should be reported (i) on Schedule F (Form 1040), Profit or Loss From Farming, as farming income from a trade or business, (ii) on a Schedule E (Form 1040), Supplemental Income and Loss, as rental income from real estate, or (iii) on a Form 4835, Farm Rental Income and Expenses, as rental income from crop or livestock production. |
| 200325001(PDF, 106K) |
6/20/2003 |
| Issue: Whether, under the facts described, the accumulated funds held by Taxpayer for certain funding agreements constitute amounts necessary to satisfy obligations arising under insurance or annuity contracts not involving life contingencies, as described in § 807(c)(3) of the Internal Revenue Code, or a reserve item described in § 807(c)(4). |
