| 200334044(PDF, 691K) |
5/30/2003 |
| Requested rulings: (1) The distribution from IRA X of fifty percent of the balance in IRA X was not required under § 408(a)(6) and the applicable minimum distribution regulations. (2) The distribution may be redeposited into IRA X despite the expiration of the 60-day rollover period provided for in Code § 408(d)(3), and if the distribution is so redeposited, Taxpayer A will not be required to include the distribution in her gross income for 2001 under Code § 408(d). |
| 200334043(PDF, 623K) |
5/29/2003 |
| Request for a private letter ruling dated March 26, 2001, concerning whether a reversion of excess amounts in Plan X, a defined benefit plan, upon its termination would be subject to the excise tax described in § 4980 of the Internal Revenue Code. |
| 200334042(PDF, 606K) |
5/28/2003 |
| Ruling request concerning the federal income tax treatment, under § 414(h)(2) of the Internal Revenue Code, of certain contributions to Plan X. |
| 200334041(PDF, 760K) |
5/28/2003 |
| Request that the Internal Revenue Service to Issue: a series of letter rulings under § 40 1 (a)(4), 404,415, and 4972 of the Internal Revenue Code. |
| 200334040(PDF, 249K) |
5/30/2003 |
| Request for a ruling, dated March 22, 2002, submitted by your authorized representative, concerning § 403(b) and 7701 of the Internal Revenue Code. |
| 200334039(PDF, 108K) |
5/30/2003 |
| Request with respect to the above-referenced defined benefit pension plan pursuant to Rev. Proc. 90-49 C.B. 620, for the plan year commencing. |
| 200334038(PDF, 475K) |
5/30/2003 |
| This letter constitutes notice that, with respect to the above-named defined benefit pension plan, the five plan amendments described below are reasonable and provide for de minimis increases in plan liabilities of the Plan within the meaning of § 401 (a)(33)(A) of the Internal Revenue Code and § 204(i)(l) of the Employment Retirement Income Security Act of 1974 (ERISA). |
| 200334037(PDF, 66K) |
8/22/2003 |
| Request for rulings on certain Federal income tax consequences of a partially consummated and proposed transaction. |
| 200334036(PDF, 47K) |
8/22/2003 |
| In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending December 31, to a taxable year ending June 30. The taxpayer has requested that the Form 1128 be considered timely filed under the authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200334035(PDF, 46K) |
8/22/2003 |
| Requesting a ruling under § 1362(g) of the Internal Revenue Code. |
| 200334034(PDF, 44K) |
8/22/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200334033(PDF, 46K) |
8/22/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200334032(PDF, 46K) |
8/22/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200334031(PDF, 69K) |
8/22/2003 |
| Requesting as to when each wind turbine generator (WTG) in its Project is “placed in service” for purposes of the allowance for depreciation under § 167 and 168 of the Internal Revenue Code and the renewable energy production credit under § 45. |
| 200334030(PDF, 59K) |
8/22/2003 |
| Requesting a ruling on behalf of the Trust and its beneficiaries that the terminating distributions from the Trust will not result in gain or loss to the Trust or its beneficiaries. |
| 200334029(PDF, 57K) |
8/22/2003 |
| Requesting a ruling under § 301.9100-(3)(a) of the Procedure and Administration Regulations that P be granted an extension of time to file an election to treat Q1 and Q2 as qualified subchapter S subsidiaries under § 1361(b)(3) of the Internal Revenue Code, effective D2, and to treat Q3 as a qualified subchapter S subsidiary under § 1361(b)(3), effective D3. |
| 200334028(PDF, 44K) |
8/22/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200334027(PDF, 57K) |
8/22/2003 |
| Requesting a ruling under § 301.9100-(3)(a) of the Procedure and Administration Regulations that P be granted an extension of time to file an election to treat Q2 as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code, effective D2. |
| 200334026(PDF, 55K) |
8/22/2003 |
| Requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations for Taxpayer to file a copy of a Form 3115, Application for Change in Accounting Method, with the IRS national office. |
| 200334025(PDF, 55K) |
8/22/2003 |
| Ruling was requested under § 2501 of the Internal Revenue Code concerning the federal gift tax consequences of a proposed exercise of a power of adjustment under State law. |
| 200334024(PDF, 49K) |
8/22/2003 |
| 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. |
| 200334023(PDF, 46K) |
8/22/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200334022(PDF, 46K) |
8/22/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200334021(PDF, 52K) |
8/22/2003 |
| Requesting a ruling that the income of the Corporation will be excludable from gross income under § 115 of the Internal Revenue Code and that the Corporation is not required to file annual information returns. |
| 200334020(PDF, 61K) |
8/22/2003 |
| Requested a ruling concerning an adjustment to your unified credit/applicable credit amount under § 2505 of the Internal Revenue Code, as described below. |
| 200334019(PDF, 21K) |
8/22/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of the generation-skipping transfer exemption to a transfer to a trust. |
| 200334018(PDF, 68K) |
8/22/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of the generation-skipping transfer exemption to a transfer to a trust. |
| 200334017(PDF, 51K) |
8/22/2003 |
| Requesting a ruling that X’s election to be treated as an S corporation was an inadvertent invalid election under § 1362(f) of the Internal Revenue Code. |
| 200334016(PDF, 47K) |
8/22/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200334015(PDF, 45K) |
8/22/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200334014(PDF, 49K) |
8/22/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200334013(PDF, 46K) |
8/22/2003 |
| Ruling request submitted on behalf of the Taxpayer concerning whether amounts received as retirement disability benefits are excludable from the gross income of the Taxpayer under § 104(a)(1) of the Internal Revenue Code. |
| 200334012(PDF, 48K) |
8/22/2003 |
| Requesting a ruling that C be granted an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200334011(PDF, 61K) |
8/22/2003 |
| Requesting a ruling that the repayment of a portion of a bond loan and redemption of a portion of the Project's tax-exempt bonds 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). |
| 200334010(PDF, 82K) |
8/22/2003 |
| Requesting a letter ruling concerning whether the transfer of interconnection facilities to Taxpayer is a nonshareholder contribution to capital excludable from Taxpayer’s income under § 118(a) of the Internal Revenue Code. |
| 200334009(PDF, 56K) |
8/22/2003 |
| Requesting a ruling under § 301.9100-3 of the Procedure and Administration Regulations that X be granted an extension of time to make an election to be disregarded as an entity separate from its owner under § 301.7701-3. |
| 200334008(PDF, 45K) |
8/22/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200334007(PDF, 47K) |
8/22/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200334006(PDF, 48K) |
8/22/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200334005(PDF, 67K) |
8/22/2003 |
| Issues: Whether, under the facts described, certain expenses incurred by Taxpayer in order to diversify its offerings of life insurance and annuity products, and to expand its distribution channels, constitute capital expenditures under § 263(a) of the Internal Revenue Code. |
| 200334004(PDF, 13K) |
8/22/2003 |
| *PULLED* |
| 200334003(PDF, 48K) |
8/22/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code for inadvertent termination of S election. |
| 200334002(PDF, 48K) |
8/22/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code for inadvertent termination of S election. |
| 200334001(PDF, 20K) |
8/22/2003 |
| Issues: (1) Whether Controlled’s sale of certain of its warrants to S9 constitutes a bargain sale of the warrants within the meaning of § 482 of the Internal Revenue Code. (2) If Controlled’s sale of the warrants constitutes a bargain sale, whether the transaction should be recast under Rev. Rul. 69-630 as a cash distribution of the bargain portion of the sale to the common parent followed by a capital contribution of such cash to S9. |
| 200333039(PDF, 815K) |
5/20/2003 |
| Request for a private letter ruling dated March 27, 2002, supplemented by additional correspondence dated January 31, 2003 and March 20, 2003, submitted on your behalf by your authorized representative, regarding the federal income tax treatment of certain contributions to Plan X under § 414(h) of the Internal Revenue Code. |
| 200333038(PDF, 579K) |
5/21/2003 |
| Ruling request, concerning the income tax treatment of certain employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200333037(PDF, 837K) |
6/19/2003 |
| Requested certain rulings with respect to a proposed transfer of assets from B to C as amended in a letter dated June 12, 2003. |
| 200333036(PDF, 841K) |
6/19/2003 |
| Requested certain rulings with respect to a proposed transfer of assets from B to C as amended in a letter dated June 12, 2003. |
| 200333035(PDF, 623K) |
5/20/2003 |
| Request relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200333034(PDF, 906K) |
5/22/2003 |
| Ruling request dated January 24, 2003, submitted on behalf of M by its attorney, relating to the tax consequences of the expanded activities of M. |
| 200333033(PDF, 557K) |
5/21/2003 |
| Requested rulings on their behalf that income received by A, B, and C from D, a limited liability company, does not constitute unrelated business taxable income under § 512(a)(l) of the Internal Revenue Code. |
| 200333032(PDF, 562K) |
5/21/2003 |
| Requested rulings on their behalf that income received by A, B, and C from D, a limited liability company, does not constitute unrelated business taxable income under § 512(a)(l) of the Internal Revenue Code. |
| 200333031(PDF, 568K) |
5/21/2003 |
| Requested rulings on their behalf that income received by A, B, and C from D, a limited liability company, does not constitute unrelated business taxable income under § 512(a)(l) of the Internal Revenue Code. |
| 200333030(PDF, 498K) |
5/23/2003 |
| Requesting rulings that the sale of real property to a private foundation will not be a direct or indirect act of self-dealing under § 4941 (d)(l)(A) of the Internal Revenue Code as to T , F, F1 or F2. |
| 200333029(PDF, 63K) |
8/15/2003 |
| Requesting a 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). |
| 200333028(PDF, 60K) |
8/15/2003 |
| Requested an extension of time to make a late election to include part of net capital gains from the dispositions of property held for investment in investment income under §163(d)(4)(B)(iii) of the Internal Revenue Code for Year1 and Year2. |
| 200333027(PDF, 64K) |
8/15/2003 |
| Requesting an 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. |
| 200333026(PDF, 50K) |
8/15/2003 |
| Requesting that the Service grant an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an entity classification election. |
| 200333025(PDF, 44K) |
8/15/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200333024(PDF, 75K) |
8/15/2003 |
| Rulings were requested regarding the federal income tax consequences of proposed transactions described below. |
| 200333023(PDF, 53K) |
8/15/2003 |
| Requesting a ruling under § 2518 of the Internal Revenue Code. |
| 200333022(PDF, 45K) |
8/15/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200333021(PDF, 47K) |
8/15/2003 |
| Requesting a ruling, under § 301.9100-3 of the Procedure and Administration Regulations, that X 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). |
| 200333020(PDF, 52K) |
8/15/2003 |
| Request that we further supplement our letter ruling dated June 25, 2002 (PLR-100157-02) (“Original Letter Ruling”), as supplemented by our letter ruling dated August 27, 2002 (PLR-138103-02) (“First Supplemental Letter Ruling” ) (collectively, the “Prior Letter Rulings”). |
| 200333019(PDF, 57K) |
8/15/2003 |
| Requesting an extension of time, under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code, to make an allocation of Decedent’s generation-skipping transfer exemption to a transfer to an irrevocable trust. |
| 200333018(PDF, 58K) |
8/15/2003 |
| Rulings were requested as to the federal income tax consequences of a proposed transaction. |
| 200333017(PDF, 49K) |
8/15/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200333016(PDF, 50K) |
8/15/2003 |
| 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. |
| 200333015(PDF, 53K) |
8/15/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Parent and Subsidiary to make an election to file a consolidated Federal income tax return, with Parent as the common parent, under § 1.1502-75(a)(1) of the Income Tax Regulations, effective for their taxable year ending on Date 2. |
| 200333014(PDF, 54K) |
8/15/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested in order to allow Parent and Foreign Subsidiary to file an election to restore value under § 1.382-8(h) of the Income Tax Regulations. |
| 200333013(PDF, 77K) |
8/15/2003 |
| The trustees of Trust request rulings regarding the proposed division of Trust, a charitable remainder unitrust, into two separate trusts, Trust A and Trust B. |
| 200333012(PDF, 49K) |
8/15/2003 |
| Requesting a ruling under § 301.9100-3 of the Procedure and Administration Regulations to file a late entity classification election. |
| 200333011(PDF, 54K) |
8/15/2003 |
| Requesting an extension of time to make an election under § 42(f)(1) of the Internal Revenue Code pursuant to § 301.9100-1 of the Procedure and Administration Regulations. |
| 200333010(PDF, 47K) |
8/15/2003 |
| Requesting that Taxpayer be granted an extension of time under Treasury Regulation § 301.9100-3 to file the election and agreement described in § 1.1503-2(g)(2)(i) with respect to the dual consolidated losses of Entity incurred in the tax year ended on date 1; and to file with the income tax return ended on date 1 the annual certification described in § 1.1503-2(g)(2)(vi)(B) with respect to the dual consolidated losses incurred by Entity in the tax year ended on date (2) Additional information was submitted on March 23, 2003. |
| 200333009(PDF, 49K) |
8/15/2003 |
| Requesting a ruling under § 301.9100-3 of the Procedure and Administration Regulations to file a late entity classification election. |
| 200333008(PDF, 54K) |
8/15/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200333007(PDF, 44K) |
8/15/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200333006(PDF, 44K) |
8/15/2003 |
| Requesting permission for Corporation to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200333005(PDF, 44K) |
8/15/2003 |
| Requesting a ruling concerning the proposed transfer of a portion of the funds of an insurance reserve fund to a voluntary employees’ beneficiary association (VEBA) trust and the proposed transfer of the remainder of the funds of the insurance reserve fund to a different insurance reserve fund. |
| 200333004(PDF, 50K) |
8/15/2003 |
| Requests an extension of time to file an election under § 855(a) of the Internal Revenue Code. |
| 200333003(PDF, 135K) |
8/15/2003 |
| Issue: Whether contributions made pursuant to a § 403(b) plan under the cInternal Revenue Codeumstances described below are made by reason of “salary reduction agreements” and therefore are wages for Federal Insurance Contributions Act (FICA) tax purposes under § 3121(a)(5)(D). |
| 200333002(PDF, 44K) |
8/15/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200333001(PDF, 53K) |
8/15/2003 |
| Issues: (1) Is X, a dump truck, excepted from the definition of a highway vehicle under § 48.4061(a)-1(d)(2)(ii) of the Manufacturers and Retailers Excise Tax Regulations (the off highway vehicle exception) so that Taxpayer is not liable for the tax imposed by § 4051(a)(1) of the Internal Revenue Code on its sale of X? (2) Whether Taxpayer is not liable for tax if, at the time X was sold, the purchaser certified to Taxpayer that X was purchased for off-road use? (3) If the IRS rules adversely to Taxpayer on Issues: (1) and (2), will the IRS grant Taxpayer’s request to apply this technical advice memorandum on a nonretroactive basis under § 7805(b)(8)? |
| 200332026(PDF, 360K) |
5/14/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200332025(PDF, 74K) |
8/8/2003 |
| Issue: Do payments received by the Taxpayer’s subsidiaries, regulated telecommunications service providers, from Federal and state low-income and high cost universal service programs constitute a contribution to capital under § 118(a) of the Internal Revenue Code? |
| 200332024(PDF, 22K) |
8/8/2003 |
| Requesting a ruling that A’s loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200332023(PDF, 12K) |
5/12/2003 |
| *PULLED* |
| 200332022(PDF, 132K) |
5/12/2003 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plans we have granted conditional waivers of the minimum funding standard for the plan years ending December 31, 1996. |
| 200332021(PDF, 183K) |
5/12/2003 |
| 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 ending November 30, 2002. |
| 200332020(PDF, 488K) |
5/15/2003 |
| Ruling request dated October 8, 2002 which requests an extension of the period within which you are permitted to dispose of your excess business holdings under § 4943 of the Internal Revenue Code. |
| 200332019(PDF, 1.2M) |
5/13/2003 |
| Ruling request dated March 7, 2003, submitted on behalf of M and N by their authorized representatives, with respect to a State-wide scholarship program, O, funded by M and administered by N. |
| 200332018(PDF, 1.3M) |
5/13/2003 |
| Ruling request dated March 7, 2003, submitted on behalf of M and N by their authorized representatives, with respect to a State-wide scholarship program, O, funded by M and administered by N. |
| 200332017(PDF, 45K) |
8/8/2003 |
| Requesting a ruling on behalf of Corporation under § 1362(b)(5) of the Internal Revenue Code. |
| 200332016(PDF, 49K) |
8/8/2003 |
| Requesting a 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. |
| 200332015(PDF, 16K) |
8/8/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200332014(PDF, 13K) |
8/8/2003 |
| Request for our consent to Taxpayer’s revocation of its election under § 831(b) to be taxed only on its investment income effective for Year 17. |
| 200332013(PDF, 54K) |
8/8/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser is requesting an extension to file a “§ 338 election” under § 338(g) with respect to Purchaser’s acquisition of the stock of Target, on Date B. |
| 200332012(PDF, 48K) |
8/8/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200332011(PDF, 24K) |
8/8/2003 |
| Request for rulings regarding certain federal income tax consequences of a proposed transaction. |
| 200332010(PDF, 48K) |
8/8/2003 |
| Requesting a 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. |
| 200332009(PDF, 16K) |
8/8/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Taxpayer's generation-skipping transfer tax exemption to certain transfers to an irrevocable trust. |
| 200332008(PDF, 12K) |
8/8/2003 |
| 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 § 4731 of the Internal Revenue Code of 1986, as amended, pursuant to the U.S. - Switzerland Income Tax Convention. |
| 200332007(PDF, 44K) |
8/8/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200332006(PDF, 53K) |
8/8/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Taxpayer’s generation-skipping transfer tax exemption. |
| 200332005(PDF, 52K) |
8/8/2003 |
| Request that the IRS rule that (1) the “grandfather clause” of Rev. Rul, 89-81, 1989-1 C.B. 226, will apply to certain preferred shares of Fund; (2) the payment of dividends by Fund on these preferred shares will not be considered preferential dividends under § 562(c) of the Internal Revenue Code of 1986; and (3) dividends paid by Fund will be eligible for the dividends received deduction under § 243 in accordance with Fund’s designation. |
| 200332004(PDF, 47K) |
8/8/2003 |
| Requesting a ruling that Taxpayers be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 469(c)(7)(A) of the Internal Revenue Code and § 1.469-9(g)(3) of the Income Tax Regulations to treat all interests in rental real estate as a single rental real estate activity. |
| 200332003(PDF, 49K) |
8/8/2003 |
| Request filed regarding the late filing of a Form 8716, Election To Have a Tax Year Other Than a Required Tax Year. 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. |
| 200332002(PDF, 36K) |
8/8/2003 |
| Requesting a ruling under § 7704 of the Internal Revenue Code. |
| 200332001(PDF, 144K) |
8/8/2003 |
| Requests of the following rulings: The “Committee Method” described above is, (i) a permissible approach under subchapter T for dividing proceeds each year among Coop A’s open crop pools, (ii) consistent with “operating on a cooperative basis” as that term is used in § 521(b)(1) and 1381(a)(2) of the Code, and (iii) consistent with the principle of “equitable allocation” enunciated in Rev. Ruls. 72-547 and 74-567. |
| 200331010(PDF, 775K) |
5/9/2003 |
| Requested rulings on your behalf under § 414(e) of the Internal Revenue Code |
| 200331009(PDF, 122K) |
5/9/2003 |
| 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 November 30,2002. |
| 200331008(PDF, 1.2M) |
5/9/2003 |
| Request rulings under § 501,4944,4942, and 4945 of the Internal Revenue Code with respect to proposed loans to promote the development and construction of housing in the downtown area of the City as described below. |
| 200331007(PDF, 1.2M) |
5/9/2003 |
| Request rulings under § 501,4944,4942, and 4945 of the Internal Revenue Code with respect to proposed loans to promote the development and construction of housing in the downtown area of the City as described below. |
| 200331006(PDF, 1.2M) |
5/9/2003 |
| Request rulings under § 501,4944,4942, and 4945 of the Internal Revenue Code with respect to proposed loans to promote the development and construction of housing in the downtown area of the City as described below. |
| 200331005(PDF, 1.2M) |
5/9/2003 |
| Request rulings under § 501,4944,4942, and 4945 of the Internal Revenue Code with respect to proposed loans to promote the development and construction of housing in the downtown area of the City as described below. |
| 200331004(PDF, 757K) |
5/8/2003 |
| Request relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200331003(PDF, 578K) |
5/9/2003 |
| Request for a ruling concerning the treatment of certain contributions made to Plan X and Plan Y under § 414(h)(2) of the Internal Revenue Code. |
| 200331002(PDF, 67K) |
8/1/2003 |
| Request for additional guidance regarding Issues: raised by the Taxpayer related to our previous technical advice memorandum TAM-115287-01 (TAM 200310001). |
| 200331001(PDF, 80K) |
8/1/2003 |
| Issues: (1) Whether Country K’s modified income tax and the X Tax applicable to Taxpayer Subsidiary in Years 1 through 6 are separate levies under Treasury Regulation §1.901-2A(a)(1); (2) Whether the X Tax satisfies the net income requirement of Treas. Reg. §1.901-2(b) and qualifies as a creditable tax under § 901; (3) Whether the X Tax is imposed “in substitution for” the modified Country K income tax and satisfies the substitution requirement of § 903; and (4) What is the correct application of the safe harbor formula in this case. |
| 200330047(PDF, 642K) |
4/28/2003 |
| Requested a ruling on behalf of the Trustees of the above-named pension plan regarding the application of § 413(b)(7) of the Internal Revenue Code in determining the deductibility of contributions made to the plan for the plan years ending on December 31,2000 and December 31, 2001. |
| 200330046(PDF, 554K) |
5/1/2003 |
| Issues: (1) The establishment, operation, and funding of Plan B will not cause Plan A to lose its qualified status under § 401 (a) of the Internal Revenue Code (Code). (2) Contributions made to Plan B, if otherwise deductible, will be deductible by the employers under § 404 of the Code. (3) Employer payments to Plan B of employer portions of applicable employment taxes under § 162 of the Code in the taxable year in which Plan B disburses those payments to the applicable taxing authorities. (4) Employer payments to Plan B to reimburse Plan B's administrative expenses are deductible under § 162 of the Code in the taxable year in which Plan B disburses those payments to the administrative service providers. |
| 200330045(PDF, 534K) |
5/1/2003 |
| Request relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200330044(PDF, 160K) |
4/29/2003 |
| This letter constitutes notice that our ruling letter, which granted a conditional waiver of the minimum funding standard for the above-named pension plan for the plan year beginning July 23, 2001, is hereby modified to replace conditions (1) and (2) of that letter with the new conditions stated below. |
| 200330043(PDF, 563K) |
4/30/2003 |
| Request a ruling that Plan X will not retain any basis in the after tax contributions once the after tax contributions are transferred to Plan Y. |
| 200330042(PDF, 641K) |
4/30/2003 |
| Requested a ruling as to whether the qualified status of Plan X as a church plan within the meaning of § 414(e) of the Internal Revenue Code would be affected if the employees of three related for-profit entities (Corporation C, Corporation D and Corporation E) participate in Plan X. |
| 200330041(PDF, 51K) |
7/25/2003 |
| Issue: After a senior lienor gives notice to the Internal Revenue Service and sells taxpayer’s property under Internal Revenue Code § 7425(d), will the Service’s right of redemption within the 120-day redemption period be extinguished by another senior lienor foreclosing on the same property. |
| 200330040(PDF, 13K) |
7/25/2003 |
| Requesting that Taxpayer be granted an extension of time under Treasury Regulation § 301.9100-3 to file the following elections: (1) the agreement described in § 1.1503-2A(c)(3) in accordance with Schedule A; (2) to replace the agreements filed under § 1.1503-2A(c)(3) in accordance with Schedule A with the election and agreement described in § 1.1503-2(g)(2)(i), pursuant to the transitional rule described in § 1.1503-2(h)(2)(ii), in accordance with Schedule B; (3) the election and agreement described in § 1.1503-2(g)(2)(i) in accordance with Schedule C; and (4) the annual certification described in § 1.1503-2(g)(2)(vi)(B) in accordance with Schedule D. Schedules A, B, C and D are made a part of this ruling letter. |
| 200330039(PDF, 119K) |
7/25/2003 |
| Ruling is requested 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, pursuant to the United States-Ireland income tax convention. |
| 200330038(PDF, 46K) |
7/25/2003 |
| Requesting that Taxpayer be granted an extension of time under Treasury Regulation § 301.9100-3 to file an election and agreement as provided under § 1.1503-2(g)(2)(i) for the tax years of Entity ended on dates 1 and 2; and to file an annual certification as provided in § 1.1503-2(g)(2)(vi)(B) for the tax year of Entity ended on date 3 with respect to the losses incurred by Entity in each of its tax years ended on dates 1 and 2. |
| 200330037(PDF, 46K) |
7/25/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200330036(PDF, 56K) |
7/25/2003 |
| Requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A’s loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200330035(PDF, 119K) |
7/25/2003 |
| Ruling is requested 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, pursuant to the United States-Ireland income tax convention. |
| 200330034(PDF, 9K) |
7/25/2003 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending December 31, to a taxable year ending September 30, effective for the tax year beginning January 1, 2002, and ending September 30, 2002. The taxpayer has requested that the Form 1128 be considered timely filed under the authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200330033(PDF, 51K) |
7/25/2003 |
| Requesting a ruling with respect to the Plan, which X intends to be an eligible deferred compensation plan under § 457 of the Internal Revenue Code of 1986. X is represented to be a public, governmental entity created by laws of the state of Y, which is charged with the function of operating the multi-campus state university system of the state of Y. |
| 200330032(PDF, 47K) |
7/25/2003 |
| Requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations for Company to elect under § 1361(b)(3)(B) of the Internal Revenue Code to treat Subs 1-8 as qualified subchapter S subsidiaries (QSubs). |
| 200330031(PDF, 57K) |
7/25/2003 |
| 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, pursuant to the United States-Ireland income tax convention. |
| 200330030(PDF, 45K) |
7/25/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200330029(PDF, 44K) |
7/25/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code for an untimely S corporation election. |
| 200330028(PDF, 55K) |
7/25/2003 |
| Requesting rulings under § 2055 of the Internal Revenue Code with respect to the proposed reformation of certain trusts. |
| 200330027(PDF, 59K) |
7/25/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to sever a trust into an exempt and nonexempt trust for purposes of the Generation-Skipping Transfer Tax and to make a “reverse” qualified terminable interest property (QTIP) election under § 2652(a)(3) of the Internal Revenue Code with respect to the exempt trust. |
| 200330026(PDF, 53K) |
7/25/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Decedent’s generation-skipping transfer exemption. |
| 200330025(PDF, 54K) |
7/25/2003 |
| 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. |
| 200330024(PDF, 56K) |
7/25/2003 |
| Request an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of the Generation-Skipping Transfer exemption. |
| 200330023(PDF, 61K) |
7/25/2003 |
| Requesting an extension of time to make an election under § 42(g)(1) of the Internal Revenue Code pursuant to § 301.9100-1 of the Procedure and Administration Regulations. |
| 200330022(PDF, 46K) |
7/25/2003 |
| Requesting a ruling that X be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c) to be treated as a disregarded entity, respectively, for federal tax purposes. |
| 200330021(PDF, 46K) |
7/25/2003 |
| Requesting a ruling that X be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c) to be treated as a partnership for federal tax purposes. |
| 200330020(PDF, 63K) |
7/25/2003 |
| Requesting a ruling that X be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c) to be treated as a partnership for federal tax purposes. |
| 200330019(PDF, 61K) |
7/25/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200330018(PDF, 85K) |
7/25/2003 |
| Issues: (1) Whether Retirement System’s definition of Compensation is “reasonable” within the meaning of § 31.3121(b)(7)-2(e)(2)(iii)(B) of the Employment Tax Regulations. (2) If Retirement System fails to meet the § 31.3121(b)(7)-2(e)(2)(iii)(B) standard, then whether Retirement System nevertheless meets the safe harbor minimum benefit standards provided under § 3.01(1) and 3.03(1)(b) of Rev. Proc. 91-40, 1991-2 C.B. 694. |
| 200330017(PDF, 68K) |
7/25/2003 |
| Requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to elect to treat Y as a qualified subchapter S subsidiary under § 1361(b)(3)(B) of the Internal Revenue Code. |
| 200330016(PDF, 88K) |
7/25/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Taxpayer 1’s and Taxpayer 2's generation-skipping transfer tax exemptions. |
| 200330015(PDF, 64K) |
7/25/2003 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat a subsidiary as a qualified subchapter S subsidiary under § 1361(b)(3)(B) of the Internal Revenue Code. |
| 200330014(PDF, 63K) |
7/25/2003 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat a subsidiary as a qualified subchapter S subsidiary under § 1361(b)(3)(B) of the Internal Revenue Code. |
| 200330013(PDF, 63K) |
7/25/2003 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat a subsidiary as a qualified subchapter S subsidiary under § 1361(b)(3)(B) of the Internal Revenue Code. |
| 200330012(PDF, 60K) |
7/25/2003 |
| Requested relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200330011(PDF, 66K) |
7/25/2003 |
| Requesting a ruling concerning the amended and restated deferred compensation plan which E intends to be an eligible deferred compensation plan under § 457(b) of the Internal Revenue Code of 1986, as amended under the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA). E is represented to be a tax-exempt organization which is an eligible employer described in § 457(e)(1)(B) of the Code. |
| 200330010(PDF, 108K) |
7/25/2003 |
| Request for a ruling that the management contract described below will not cause bonds to be issued by Issuer to finance the Facilities (as defined below), to meet the private business use test of § 141(b)(1) of the Internal Revenue Code. For this purpose, the Issuer requests a ruling that the Contract meets the requirements of Rev. Proc. 97-13, 1997-1 C.B. 692 or, in the alternative, that the Contract will not cause the Bonds to meet the private business use test under § 141(b)(1) based on all of the facts and cInternal Revenue Codeumstances. |
| 200330009(PDF, 88K) |
7/25/2003 |
| Issue: Whether Taxpayer’s request for relief under § 7805(b)(8) of the Internal Revenue Code should be granted and the determinations made in TAM (Date b) be applied without retroactive effect. |
| 200330008(PDF, 73K) |
7/25/2003 |
| Requesting a ruling that Partnership be given an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as an association taxable as a corporation for federal tax purposes and be granted relief under § 1362(f) of the Internal Revenue Code. |
| 200330007(PDF, 75K) |
7/25/2003 |
| Requesting a ruling that Partnership be given an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as an association taxable as a corporation for federal tax purposes and be granted relief under § 1362(f) of the Internal Revenue Code. |
| 200330006(PDF, 37K) |
7/25/2003 |
| Requesting a ruling that Partnership be given an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as an association taxable as a corporation for federal tax purposes and be granted relief under § 1362(f) of the Internal Revenue Code. |
| 200330005(PDF, 73K) |
7/25/2003 |
| Requesting a ruling that Partnership be given an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as an association taxable as a corporation for federal tax purposes and be granted relief under § 1362(f) of the Internal Revenue Code. |
| 200330004(PDF, 35K) |
7/25/2003 |
| Requesting a ruling that Partnership be given an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as an association taxable as a corporation for federal tax purposes and be granted relief under § 1362(f) of the Internal Revenue Code. |
| 200330003(PDF, 25K) |
7/25/2003 |
| Requesting a ruling, under § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations, that X be granted an extension of time for making an election to be treated as an association taxable as a corporation for federal tax purposes. |
| 200330002(PDF, 103K) |
7/25/2003 |
| Issue: Whether short-term capital gains included within dividends paid by a regulated investment company are taken into account by a life insurance company’s segregated asset account under the basis adjustment rules § 817(b) of the Internal Revenue Code, such that those short-term capital gains are excluded from the segregated asset account’s gross investment income under § 812(d). |
| 200330001(PDF, 154K) |
7/25/2003 |
| Issues: (1) Can Taxpayer include qualified research expenses paid or incurred by Corporation D and Corporation D Subsidiaries for the period Date 1 through Date 3 for purposes of computing its research credit for its taxable year ended Date 5? (2) How should Taxpayer compute its research credit for its taxable year ended Date 5? |
