| 200339056(PDF, 883K) |
7/3/2003 |
| Requested a private letter ruling on your behalf with respect to an arrangement described in § 403(b)(9) of the Internal Revenue Code. |
| 200339055(PDF, 626K) |
7/2/2003 |
| Request regarding whether Plans V, W, X, Y and Z which has established and maintained for the employees of Hospital H are governmental plans for purposes of § 414(d) of the Internal Revenue Code. |
| 200339054(PDF, 60K) |
9/26/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200339053(PDF, 67K) |
9/26/2003 |
| Request for a determination that Trusts A and B, Corps A through C, Partnerships A through F, and Individuals A through Q 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 § 1.1295-3. |
| 200339052(PDF, 63K) |
9/26/2003 |
| 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. |
| 200339051(PDF, 21K) |
9/26/2003 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to file the election and agreement described in §1503-2(g)(2)(i) with respect to each dual consolidated loss of Entity incurred in the tax years ended on Date 1 and on Date 2, and to file the annual certification described in § 1.1503-2(g)(2)(vi) for the tax year ended on Date 2 with respect to the dual consolidated losses of Entity incurred in the tax year ended on Date 1. |
| 200339050(PDF, 50K) |
9/26/2003 |
| Requesting a ruling regarding the application of § 216(b) of the Internal Revenue Code to Corporation. |
| 200339049(PDF, 74K) |
9/26/2003 |
| Issue: What charges are included in the term “amount retained” under § 1.801-8(e)(1) of the Income Tax Regulations in determining the amount of “required interest” under § 812(b)(2)(A) of the Internal Revenue Code? |
| 200339048(PDF, 22K) |
9/26/2003 |
| Issues: (1) Whether the IRS should decline to coverover net tax collections, attributable to individuals who may not be residents of the VI, and the returns forwarded back to the BIR with the Issue: clearly identified? (2) Alternatively, whether the PAMC should process the coverover, even though the bona fide residency is in question, and then send a copy of the return along with PAMC comments to the BIR and request that the BIR verify the bona fide residency of the taxpayer? (3) In instances where a return was filed with and processed by the IRS prior to receipt of a return for that taxpayer to be covered over, the cover over return causes a duplicate filing condition. Would the initial filing constitute the filer to be a United States taxpayer, and the PAMC would therefore not cover over the return, or should the Issue: of residency be forwarded to the BIR as in #2 above? (4) Whether the PAMC should allow all Virgin Islands coverovers as submitted by the BIR without addressing the bona fide residency Issue: even if residency is deemed questionable? |
| 200339047(PDF, 10K) |
9/26/2003 |
| Issues: (1) Whether Decedent's interest in Corporation 3 constitutes an interest in a closely held business within the meaning of § 6166(b)(1) or whether the interest in Corporation 3 constitutes a passive asset within the meaning of § 6166(b)(9). (2) Whether Decedent’s interest in Corporation 3 can be aggregated with Decedent’s interests in Corporation 1 and Corporation 2 such that Decedent is treated as owning an interest in a single closely held business pursuant to § 6166(c). |
| 200339046(PDF, 75K) |
9/26/2003 |
| Request for advice concerning the Service’s summons authority and federal restrictions on sales records of persons engaged in the fishing industry. |
| 200339045(PDF, 49K) |
9/26/2003 |
| 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. |
| 200339044(PDF, 49K) |
9/26/2003 |
| 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. |
| 200339043(PDF, 70K) |
9/26/2003 |
| Requested rule that for purposes of § 6166, certain interests in commercial rental real estate activities constitute interests in a closely held business and would not be considered passive assets. Requested rule that if the interests are not considered passive assets, then they may be treated as an interest in a single closely held business pursuant to § 6166(c). |
| 200339042(PDF, 49K) |
9/26/2003 |
| 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. |
| 200339041(PDF, 49K) |
9/26/2003 |
| Requesting a ruling that the rental income received by Company from the Property is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200339040(PDF, 49K) |
9/26/2003 |
| Requesting a ruling that the rental income received by Company from the Property is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200339039(PDF, 53K) |
9/26/2003 |
| Requesting rulings concerning the federal income tax consequences of the transactions described below. |
| 200339038(PDF, 53K) |
9/26/2003 |
| Requesting rulings concerning the federal income tax consequences of the transactions described below. |
| 200339037(PDF, 53K) |
9/26/2003 |
| Requesting rulings concerning the federal income tax consequences of the transactions described below. |
| 200339036(PDF, 53K) |
9/26/2003 |
| Requesting rulings concerning the federal income tax consequences of the transactions described below. |
| 200339035(PDF, 55K) |
9/26/2003 |
| Request for a ruling that Company is an instrumentality of Authority for the purposes of § 141 of the Internal Revenue Code. |
| 200339034(PDF, 48K) |
9/26/2003 |
| 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. |
| 200339033(PDF, 48K) |
9/26/2003 |
| 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. |
| 200339032(PDF, 53K) |
9/26/2003 |
| Requesting rulings concerning the federal income tax consequences of the transactions described below. |
| 200339031(PDF, 53K) |
9/26/2003 |
| Requesting rulings concerning the federal income tax consequences of the transactions described below. |
| 200339030(PDF, 61K) |
9/26/2003 |
| Request for revised schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200339029(PDF, 61K) |
9/26/2003 |
| Request for revised schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200339028(PDF, 60K) |
9/26/2003 |
| Requesting rulings under § 7701(h) of the Internal Revenue Code. |
| 200339027(PDF, 44K) |
9/26/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200339026(PDF, 46K) |
9/26/2003 |
| Requesting rulings under § 301.7701-3(b)(1)(ii) of the Procedure and Administration Regulations and § 1361(c)(2)(A)(i) of the Internal Revenue Code. |
| 200339025(PDF, 62K) |
9/26/2003 |
| 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. |
| 200339024(PDF, 44K) |
9/26/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200339023(PDF, 49K) |
9/26/2003 |
| Requesting an 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 to be treated as an S corporation under § 1362(b)(5) of the Internal Revenue Code. |
| 200339022(PDF, 60K) |
9/26/2003 |
| Requesting a private letter ruling under § 42 of the Internal Revenue Code. |
| 200339021(PDF, 53K) |
9/26/2003 |
| Requesting a ruling concerning the gift tax consequences of the release of the right to receive distributions from a trust. |
| 200339020(PDF, 47K) |
9/26/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200339019(PDF, 44K) |
9/26/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200339018(PDF, 59K) |
9/26/2003 |
| Request rulings regarding the effect of the creation of the proposed charitable "lead" trust for federal gift and income tax purposes. |
| 200339017(PDF, 48K) |
9/26/2003 |
| Ruling request, that payments to participating employees under the Plan are excludable from their income. |
| 200339016(PDF, 51K) |
9/26/2003 |
| Requesting a ruling concerning the federal income tax treatment of benefits received under certain life insurance contract riders. |
| 200339015(PDF, 51K) |
9/26/2003 |
| Requesting a ruling concerning the federal income tax treatment of benefits received under certain life insurance contract riders. |
| 200339014(PDF, 48K) |
9/26/2003 |
| Requesting permission for Taxpayer and the members of its § 41(f)(5) controlled group to revoke an election under § 41(c)(4) of the Internal Revenue Code. |
| 200339013(PDF, 44K) |
9/26/2003 |
| Requesting permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200339012(PDF, 45K) |
9/26/2003 |
| Request for a supplemental ruling confirming that the Corporation may continue to rely on the conclusions set forth in the private letter ruling previously Issued to Corporation on Date 1 (the Prior Ruling). |
| 200339011(PDF, 49K) |
9/26/2003 |
| Request for an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to file Form 8328 (Carryforward Election of Unused Private Activity Bond Volume Cap) for the Authority to make a carryforward election under § 146(f) of the Internal Revenue Code with respect to x in unused volume cap for year 2002.1 |
| 200339010(PDF, 53K) |
9/26/2003 |
| Requesting a ruling that the reporting of purchases of qualified replacement property filed with Taxpayer's 2002 income tax return will be treated as having substantially complied with the requirements of § 1.1042-1T of the Temporary Income Tax Regulations in connection with the sale of stock of the Company to the employee stock ownership plan (ESOP) maintained by the Company. |
| 200339009(PDF, 48K) |
9/26/2003 |
| Ruling request concerning the use of average area purchase price limitations based upon more accurate and comprehensive data than that used to calculate the safe harbor limitations published in Rev. Proc. 94-55, 1994-2 C.B. 706. |
| 200339008(PDF, 44K) |
9/26/2003 |
| Requesting a supplemental letter ruling with respect to our prior letter ruling (PLR-155976-01) dated February 12, 2002 (the ”Prior Letter Ruling”). |
| 200339007(PDF, 58K) |
9/26/2003 |
| Requesting rulings concerning the federal income tax consequences of a proposed transaction. |
| 200339006(PDF, 50K) |
9/26/2003 |
| Request for a ruling to determine the federal employment tax status of the above-named Worker with respect to services provided for a federal agency from August, 2001 through September, 2002. |
| 200339005(PDF, 50K) |
9/26/2003 |
| 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. |
| 200339004(PDF, 61K) |
9/26/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200339003(PDF, 58K) |
9/26/2003 |
| Issue: If a trust for the benefit of Spouse is funded, in part, with stock that has never paid dividends, does that portion of the trust qualify for the federal estate tax marital deduction as qualified terminable interest property (QTIP) under § 2056(b)(7) of the Code? |
| 200339002(PDF, 32K) |
9/26/2003 |
| Requested rulings regarding Internal Revenue Code § 118 and 216. By letter dated May 9, 2003, you withdrew your request for a ruling under § 216. Accordingly, this letter addresses only whether the Special Assessments described below qualify as contributions to capital under § 118(a). |
| 200339001(PDF, 34K) |
9/26/2003 |
| Ruling request concerning the federal income tax and employment tax treatment of medical and dental benefits provided by Taxpayers to the domestic partners of employees. |
| 200338023(PDF, 1.1M) |
6/25/2003 |
| Ruling request concerning the federal tax consequences of the transfer of various assets from a trust described in § 501 (c)(9) of the Internal Revenue Code to a similar trust and the allocation of assets in one trust to subtrusts in the other trust. |
| 200338022(PDF, 480K) |
6/26/2003 |
| Requested a ruling concerning the federal income tax treatment of certain contributions to Plan X under § 414(h)(2) of the-Internal Revenue Code. |
| 200338021(PDF, 589K) |
6/26/2003 |
| Request rulings concerning whether Plan X is a church plan described in § 414(e) of the Internal Revenue Code and has continued to meet the requirements of § 414(e) since its inception and certain related questions. |
| 200338020(PDF, 602K) |
6/23/2003 |
| Requested a ruling on your behalf under § 414(e) of the Internal Revenue Code |
| 200338019(PDF, 737K) |
6/27/2003 |
| Requested a ruling regarding the status of Plan X as a church plan described in § 414(e) of the Internal Revenue Code. |
| 200338018(PDF, 557K) |
6/26/2003 |
| Ruling request submitted on your behalf by your authorized representative dated June 28, 2002, as supplemented by correspondence dated November 14,2002, March 26, 2003 and June 12,2003, with respect to the federal income tax treatment of certain contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200338017(PDF, 222K) |
6/23/2003 |
| Request for waiver for the plan year ended December 31,2001 in accordance with § 412(d) of the Internal Revenue Code and § 303 of the Employee Retirement Income Security Act of 1974 (ERISA). |
| 200338016(PDF, 99K) |
6/26/2003 |
| Request for a waiver of the minimum funding standard for the plan year ended December 31,2001 with respect to the above-named defined benefit pension plan. |
| 200338015(PDF, 45K) |
9/19/2003 |
| Requested rulings concerning the proper income, gift, and generation-skipping transfer (“GST”) tax treatment of the domestication of a foreign trust. |
| 200338014(PDF, 19K) |
9/19/2003 |
| Issues: Whether the Mississippi Department of Transportation (DOT) qualifies under Internal Revenue Code § 6103(d)(1) as a state agency charged under the laws of Mississippi with responsibility to administer the state tax laws? |
| 200338013(PDF, 21K) |
9/19/2003 |
| Issue: Who is authorized to sign the Reporting Agent Authorization for Magnetic Tape/Electronic Filers (Form 8655) when the taxpayer identification number (TIN) or the employer identification number (EIN) on the Form 8655 belongs to a sole proprietorship or a limited liability company (LLC)? |
| 200338012(PDF, 25K) |
9/19/2003 |
| Issues: Whether a disregarded Limited Liability Company (LLC) is an “other person” for purposes of collecting employment taxes under § 3505(a). |
| 200338011(PDF, 72K) |
9/19/2003 |
| Issues: (1) Under the rules of § 83 of the Internal Revenue Code, when was the compensation income attributable to Taxpayer A’s exercises of certain incentive stock options includible in his alternative minimum taxable income. (2) Under the rules of § 83, how is the amount of compensation income computed. |
| 200338010(PDF, 75K) |
9/19/2003 |
| Issues: (1) Under the rules of § 83 of the Internal Revenue Code, when was the compensation income attributable to Taxpayer A’s exercises of certain incentive stock options includible in his alternative minimum taxable income. (2) Under the rules of § 83, how is the amount of compensation income computed. |
| 200338009(PDF, 187K) |
9/19/2003 |
| Issues: (1) Whether the transactions lack economic substance. (2) Alternatively, whether the transactions should be recharacterized as a financing, rather than a sale-leaseback. (3) Whether A received original Issue: discount income as a result of the transactions. (4) Whether A is liable for negligence penalties, pursuant to § 6662, for entering into the transactions. |
| 200338008(PDF, 50K) |
9/19/2003 |
| Requesting a ruling that the rental income X received is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200338007(PDF, 52K) |
9/19/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200338006(PDF, 54K) |
9/19/2003 |
| Requesting rulings under § 664 and 4941 of the Internal Revenue Code concerning the effect of a judicial reformation of Trust on the qualification of Trust as a charitable remainder unitrust under § 664. |
| 200338005(PDF, 65K) |
9/19/2003 |
| Request for 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 Settlor’s and Wife’s remaining GST exemption to transfers to B Irrevocable Trust - Grandchildren, a life insurance trust. |
| 200338004(PDF, 58K) |
9/19/2003 |
| Request for a ruling that bonds to be Issued to finance certain costs of constructing, renovating, improving, equipping, furnishing, and demolishing public school facilities, will not be “hedge bonds” under §149(g)(3) of the Internal Revenue Code, and consequently, that § 149(g) does not preclude the exclusion of interest on the Bonds from gross income under § 103(a). |
| 200338003(PDF, 44K) |
9/19/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200338002(PDF, 57K) |
9/19/2003 |
| 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 Taxpayers’ generation-skipping transfer tax exemptions to certain transfers to an irrevocable trust. |
| 200338001(PDF, 75K) |
9/19/2003 |
| The Taxpayers request a ruling that Intermediary is not a “disqualified person” as defined in §1.1031(k)-1(k) of the regulations with respect to Taxpayers' like-kind exchange of property under §1031 of the Code. |
| 200337017(PDF, 454K) |
6/20/2003 |
| Requested rulings under § 401(a), 415, 402(a), 511 and 512 of the Internal Revenue Code. |
| 200337016(PDF, 709K) |
6/19/2003 |
| Ruling request with respect to the federal income tax treatment of certain contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200337015(PDF, 303K) |
6/17/2003 |
| Revocation in letter of January 15, 2003, in which it was ruled that a contemplated merger of Plan A and Plan B would not have required vesting service credit under the merged plan with regard to service before the effective date of Plan A for any Plan A participant who was never a participant in Plan B. Your authorized representative has informed us that the contemplated merger has not taken place and that you may reconsider the merger in light of this revised ruling. |
| 200337014(PDF, 218K) |
2/11/2003 |
| Request a ruling under § 408 of the Internal Revenue Code. |
| 200337013(PDF, 909K) |
6/18/2003 |
| Request for a ruling concerning an arrangement described under § 403(b) of the Internal Revenue Code. |
| 200337012(PDF, 52K) |
6/12/2003 |
| Issue: Is paragraph B of the Assignment of Limited Partnership Interest in Partnership, that transfers a fractional interest in Partnership having a certain fair market value, effective for gift tax purposes under § 2511 of the Internal Revenue Code? |
| 200337011(PDF, 58K) |
6/12/2003 |
| Requesting a ruling that the Firm’s use of a new agreement, described below, with respect to Workers, will not terminate the Firm’s relief from the imposition of federal employment taxes under § 530 of the Revenue Act of 1978. |
| 200337010(PDF, 50K) |
6/12/2003 |
| 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 an eligible employer within the meaning of § 457(e)(1)(A). |
| 200337009(PDF, 47K) |
6/12/2003 |
| 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. |
| 200337008(PDF, 53K) |
6/12/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200337007(PDF, 49K) |
6/12/2003 |
| Issue: Is the purchase of pull-tabs sold by X exempt from the definition of a wager as provided in § 4401 of the Internal Revenue Code by reason of § 4421(2)(A)? |
| 200337006(PDF, 64K) |
6/12/2003 |
| Requesting a ruling that the income of Corporation is excludable from gross income under § 115(1) of the Internal Revenue Code. |
| 200337005(PDF, 49K) |
6/12/2003 |
| Requesting a ruling under §301.9100 of the Procedure and Administration Regulations. |
| 200337004(PDF, 52K) |
6/12/2003 |
| Ruling request that payments to participants under the Plan are excluded from the income of participating employees. |
| 200337003(PDF, 57K) |
6/12/2003 |
| Request for ruling concerning whether the stock of a newly formed real estate corporation will constitute qualified replacement property within the meaning of § 1042(c)(4) of the Internal Revenue Code of 1986, and therefore, whether the sale of stock of the Company A to the employee stock ownership plan (ESOP) maintained by the company and subsequent purchase of qualified replacement property will satisfy the requirements for an election under § 1042(a) of the Code. |
| 200337002(PDF, 53K) |
6/12/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent is requesting an extension to file a “§ 338 election” under § 338(g) with respect to Parent’s acquisition of the stock of Target, on Date A. |
| 200337001(PDF, 55K) |
6/12/2003 |
| Requesting rulings under § 355 of the Internal Revenue Code with respect to a proposed transaction. |
| 200336037(PDF, 279K) |
6/11/2003 |
| Request for waiver of the minimum funding standard. This letter constitutes notice that a conditional waiver of the minimum funding standard has been granted for the above-named pension plan for the noted plan year. |
| 200336036(PDF, 113K) |
6/10/2003 |
| Ruling request 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 |
| 200336035(PDF, 330K) |
6/9/2003 |
| Requesting rulings under § 414(h)(2) of the Internal Revenue Code. |
| 200336034(PDF, 254K) |
6/12/2003 |
| Request for a ruling as to whether Plan X (i) is a plan described in § 1022(i)(l) of the Employee Retirement Income Security Act of 1974 (ERISA) and whether the investment of Plan X assets in Trust Y will not adversely affect the exempt status of Trust Y under § 501 (a) of the Internal Revenue Code. |
| 200336033(PDF, 58K) |
9/5/2003 |
| Issues: Whether the Plan meets the requirements of § 105(c) of the Internal Revenue Code? |
| 200336032(PDF, 63K) |
9/5/2003 |
| Request for a ruling that the discharge of indebtedness described below will not result in income under § 61(a)(12) of the Internal Revenue Code because it will be treated as a purchase price adjustment under Rev. Proc. 92-92, l992-2 C.B. 505. |
| 200336031(PDF, 44K) |
9/5/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200336030(PDF, 82K) |
9/5/2003 |
| Requested on your behalf rulings regarding the proper federal income tax treatment, including any information reporting obligations, of certain housing assistance payments and benefits provided by you (sometimes referred to herein as M, or the "Tribe") under the N housing program. |
| 200336029(PDF, 126K) |
9/30/2003 |
| Issues: (1) Do tax shelter registration applications (Forms 8264), the fact of registration, the registration letters the IRS sends to the registrants, and the tax shelter’s registration number constitute return information under § 6103(b)(2)(A) of the Internal Revenue Code? (2) What facts regarding registration may the IRS disclose to the tax shelter organizer, any other person participating in the organization of the tax shelter, any person participating in the sale of the tax shelter, any person participating in the management of the tax shelter, or any person investing in the tax shelter? (3) Where the tax shelter is organized as a partnership, may return information pertaining to the shelter’s registration be disclosed to members of the partnership other than the registrant? (4) Who may authorize disclosure of information related to registration of a particular tax shelter? |
| 200336028(PDF, 18K) |
9/5/2003 |
| In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, request for permission to adopt an accounting period, for federal income tax purposes. |
| 200336027(PDF, 22K) |
9/5/2003 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to file the election and agreement described in §1503-2(g)(2)(i) in accordance with Schedule A, which is attached and made a part of this ruling letter. |
| 200336026(PDF, 20K) |
9/5/2003 |
| In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, request for permission to adopt an accounting period, for federal income tax purposes. |
| 200336025(PDF, 22K) |
9/5/2003 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to attach to its U.S. income tax return for the tax year ended on Date 2 the documentation required under § 1.1503-2(g)(2)(iii)(B) to rebut the presumption that the transaction on Date 1 was a triggering event within the meaning of § 1.1503-2(g)(2)(iii)(A)(5). |
| 200336024(PDF, 22K) |
9/5/2003 |
| 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. |
| 200336023(PDF, 48K) |
9/5/2003 |
| Requesting a private letter ruling regarding § 45 of the Internal Revenue Code. |
| 200336022(PDF, 43K) |
9/5/2003 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200336021(PDF, 47K) |
9/5/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200336020(PDF, 49K) |
9/5/2003 |
| Requesting rulings under § 691 and § 642 of the Internal Revenue Code. |
| 200336019(PDF, 56K) |
9/5/2003 |
| Request for a ruling that the acquisition of certain electric power generators by Agency will not constitute the acquisition of nongovernmental output property under § 141(d)(2) of the Internal Revenue Code. |
| 200336018(PDF, 44K) |
9/5/2003 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200336017(PDF, 44K) |
9/5/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200336016(PDF, 44K) |
9/5/2003 |
| Requested relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200336015(PDF, 45K) |
9/5/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200336014(PDF, 53K) |
9/5/2003 |
| Requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make an qualified terminable interest property election under § 2056(b)(7) with respect to the portion of the Residence Property held by Decedent at his death. |
| 200336013(PDF, 48K) |
9/5/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. |
| 200336012(PDF, 48K) |
9/5/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. |
| 200336011(PDF, 48K) |
9/5/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. |
| 200336010(PDF, 48K) |
9/5/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. |
| 200336009(PDF, 68K) |
9/5/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. |
| 200336008(PDF, 68K) |
9/5/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. |
| 200336007(PDF, 68K) |
9/5/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. |
| 200336006(PDF, 68K) |
9/5/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. |
| 200336005(PDF, 47K) |
9/5/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200336004(PDF, 74K) |
9/5/2003 |
| This letter is in response to your request on behalf of the State for a ruling that the Warrants will be “obligations” of the State for purposes of § 103 of the Internal Revenue Code. |
| 200336003(PDF, 49K) |
9/5/2003 |
| Requesting a ruling regarding the allocation of Decedent’s generation-skipping transfer tax exemption. |
| 200336002(PDF, 45K) |
9/5/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200336001(PDF, 70K) |
9/5/2003 |
| Request for a ruling that the distribution of the District cable television programming by the Provider, under the facts and terms described below, does not constitute private business use under § 141(b)(1) of the Internal Revenue Code of 1986 of facilities used to produce that programming. |
| 200335037(PDF, 641K) |
6/2/2003 |
| Requested rulings with respect to certain grants under § 501(c)(3), 509(a)(3) and 4958 of the Internal Revenue Code. |
| 200335036(PDF, 578K) |
6/4/2003 |
| Ruling request dated March 15, 2002, in which you request relief under § 301.91 00-3 of the Procedure and Administration Regulations. |
| 200335035(PDF, 822K) |
6/4/2003 |
| Ruling request concerning the federal income tax consequences and treatment under § 72,401 (k)(2)(B), and 41 5 of the Internal Revenue Code of a proposed transfer of assets from one qualified retirement plan to another to purchase prior or additional service credit on behalf of the participants under the plan receiving the transferred assets. |
| 200335034(PDF, 377K) |
8/29/2003 |
| Issue: What are the tax consequences to taxpayers of the receipt of settlement proceeds for lost fishing income, devaluation of a fishing permit, and devaluation of fishing boats? |
| 200335033(PDF, 52K) |
8/29/2003 |
| Requesting a ruling that the transfer of a customer’s short sale position from its current broker to Taxpayer, in the manner described below, does not constitute “entering into” a short sale by the customer under § 1.6045-1(a)(9) of the Income Tax Regulations. |
| 200335032(PDF, 24K) |
8/29/2003 |
| Issue: Whether the distribution of $ h which takes the form of a § 305(b)(1) dividend and is followed by a recapitalization at a later date should be taxed as a dividend or as capital gain. |
| 200335031(PDF, 12K) |
8/29/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200335030(PDF, 76K) |
8/29/2003 |
| This letter responds to your letter dated November 20, 2002, and subsequent correspondence submitted on behalf of the Taxpayer involving § 42 of the Internal Revenue Code. |
| 200335029(PDF, 68K) |
8/29/2003 |
| Requesting certain rulings concerning § 671, 1.671-4(b)(3), and 1221 under the Internal Revenue Code. |
| 200335028(PDF, 9K) |
8/29/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for LLC to file an entity election under § 301.7701-3(c). |
| 200335027(PDF, 56K) |
8/29/2003 |
| Requesting a ruling under § 877(c) of the Internal Revenue Code of 1986 that A’s loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200335026(PDF, 71K) |
8/29/2003 |
| Request for a revised schedule of ruling amounts in accordance with § 1.468A-3(i)(1)(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on June 24, 1992. |
| 200335025(PDF, 9K) |
8/29/2003 |
| In reference to a Form 1128, requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending December 31, to a taxable year ending February 28, effective February 28... |
| 200335024(PDF, 55K) |
8/29/2003 |
| Requesting an extension of time pursuant to § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Taxpayers’ generation-skipping transfer exemption. |
| 200335023(PDF, 52K) |
8/29/2003 |
| This letter responds to your March 5, 2003 request that we supplement our letter ruling dated January 12, 2002 (PLR-152312-01) (Prior Letter Ruling). |
| 200335022(PDF, 48K) |
8/29/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200335021(PDF, 47K) |
8/29/2003 |
| Requesting a ruling that X be given an extension of time to elect under § 301.9100-3 of the Procedure and Administration Regulations to be classified as an association taxable as a corporation for federal tax purposes and relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200335020(PDF, 47K) |
8/29/2003 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat Y as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200335019(PDF, 52K) |
8/29/2003 |
| Requesting rulings on the federal income tax consequences of a proposed transaction. |
| 200335018(PDF, 47K) |
8/29/2003 |
| 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. |
| 200335017(PDF, 58K) |
8/29/2003 |
| Requesting rulings under § 170, 664, 1223 and 2522 of the Internal Revenue Code concerning the effect of a contribution to a charitable remainder unitrust (CRUT). With respect to this transaction, the Employee Plans Office of the Internal Revenue Service previously Issued rulings within their jurisdiction to you. |
| 200335016(PDF, 47K) |
8/29/2003 |
| Request a ruling under § 877(c) of the Internal Revenue Code on whether one of the principal purposes for A’s loss of citizenship was the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200335015(PDF, 50K) |
8/29/2003 |
| Requesting a ruling regarding the gift tax consequences of a proposed agreement regarding the exercise of a testamentary general power of appointment held by Taxpayer. |
| 200335014(PDF, 48K) |
8/29/2003 |
| 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. |
| 200335013(PDF, 70K) |
8/29/2003 |
| Requested rulings concerning the federal income tax consequences of a proposed transaction. |
| 200335012(PDF, 71K) |
8/29/2003 |
| Requested rulings concerning the federal income tax consequences of a proposed transaction. |
| 200335011(PDF, 71K) |
8/29/2003 |
| Requested rulings concerning the federal income tax consequences of a proposed transaction. |
| 200335010(PDF, 71K) |
8/29/2003 |
| Requested rulings concerning the federal income tax consequences of a proposed transaction. |
| 200335009(PDF, 71K) |
8/29/2003 |
| Requested rulings concerning the federal income tax consequences of a proposed transaction. |
| 200335008(PDF, 71K) |
8/29/2003 |
| Requested rulings concerning the federal income tax consequences of a proposed transaction. |
| 200335007(PDF, 48K) |
8/29/2003 |
| Requesting a ruling that C be granted an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200335006(PDF, 48K) |
8/29/2003 |
| Requesting a ruling that C be granted an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200335005(PDF, 48K) |
8/29/2003 |
| Requesting a ruling that C be granted an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200335004(PDF, 48K) |
8/29/2003 |
| Requesting a ruling that C be granted an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200335003(PDF, 48K) |
8/29/2003 |
| Requesting a ruling that C be granted an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200335002(PDF, 48K) |
8/29/2003 |
| Requesting a ruling that C be granted an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200335001(PDF, 48K) |
8/29/2003 |
| Requesting a ruling that C be granted an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
