| 200344028(PDF, 426K) |
8/7/2003 |
| Requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200344027(PDF, 590K) |
8/7/2003 |
| Requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200344026(PDF, 422K) |
8/7/2003 |
| Requesting advance approval of your grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200344025(PDF, 997K) |
8/6/2003 |
| Request concerning the proper treatment of a reversion from its pension plan under § 4980 of the Internal Revenue Code |
| 200344024(PDF, 513K) |
8/6/2003 |
| Request letter rulings concerning the application of § 402(c) of the Internal Revenue Code. |
| 200344023(PDF, 19K) |
10/31/2003 |
| Requesting that Taxpayer be granted an extension of time under Treasury Regulation § 301.9100-3 to file the elections required under Treas. Reg. § 1.1503-2(g)(2)(i) for Entity A and Entity B for the tax years ended on dates 1 and 2; and to file the annual certifications required under § 1.1503-2(g)(2)(vi)(B) for Entity A and Entity B for the tax year ended on date 2 with respect to the losses incurred in the tax year ended on date (1) Additional information was submitted in letters dated April 26, 2002, and November 20, 2002. The information submitted for consideration is substantially as set forth below. |
| 200344022(PDF, 81K) |
10/31/2003 |
| Ruling request regarding the tax treatment of attorneys’ fees paid by B in connection with the settlement of a class action lawsuit. |
| 200344021(PDF, 50K) |
10/31/2003 |
| Requesting that the Service grant the Trust an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 642(c)(1) of the Internal Revenue Code for its Year 1 taxable year. |
| 200344020(PDF, 66K) |
10/31/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer exemption. |
| 200344019(PDF, 50K) |
10/31/2003 |
| Requesting relief for an inadvertent invalid election under § 1362(f) of the Internal Revenue Code. |
| 200344018(PDF, 48K) |
10/31/2003 |
| Requesting a supplemental ruling with respect to our prior letter ruling PLR-122488-02. The Prior Ruling addressed the federal income tax consequences of the Distribution and related transactions, and ruled that such transactions constituted a series of transactions described in § 355(a) and 368(a)(1)(D). |
| 200344017(PDF, 53K) |
10/31/2003 |
| Requesting permission for Taxpayer to revoke an election under § 528 of the Internal Revenue Code for the taxable year ending on Date. |
| 200344016(PDF, 47K) |
10/31/2003 |
| Requesting a ruling under § 301.9100-3(a) of the Procedure and Administration Regulations granting an extension of time allowing Taxpayer to file an election effective Date 1 to be treated as a disregarded entity for federal tax purposes. |
| 200344015(PDF, 45K) |
10/31/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200344014(PDF, 52K) |
10/31/2003 |
| Request for a ruling,seeking inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200344013(PDF, 56K) |
10/31/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200344012(PDF, 57K) |
10/31/2003 |
| Requested a ruling that premiums received by the Taxpayer on policies of insurance or reinsurance of US 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. |
| 200344011(PDF, 45K) |
10/31/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200344010(PDF, 55K) |
10/31/2003 |
| Requesting a ruling under § 213 of the Internal Revenue Code. |
| 200344009(PDF, 47K) |
10/31/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200344008(PDF, 71K) |
10/31/2003 |
| Issue: Whether Internal Revenue Code § 274(a)(1)(A) disallows an S corporation’s deductions for the amount of expenses (described below) of providing corporate aInternal Revenue Coderaft for the personal use of a shareholder or employee, in excess of the value of the flights included in the shareholder’s or employee’s income under the methodology of Treasury Regulation § 1.61-21(g). |
| 200344007(PDF, 48K) |
10/31/2003 |
| Requesting permission for Taxpayer and the members of its controlled group to revoke the election under § 41(c)(4) of the Internal Revenue Code. |
| 200344006(PDF, 47K) |
10/31/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200344005(PDF, 51K) |
10/31/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200344004(PDF, 44K) |
10/31/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200344003(PDF, 59K) |
10/31/2003 |
| Requests that we rule that, for purposes of applying the diversification requirements of § 817(h) of the Internal Revenue Code to the investments supporting Taxpayer’s variable life insurance contracts and variable annuities, Taxpayer’s tax-exempt status as a fraternal benefit society under § 501(c)(8) will not cause the beneficial interests of a regulated investment company (RIC) used by Taxpayer and other insurance companies to support variable contracts to be ineligible for look-through treatment pursuant to § 817(h)(4) and Treasury Regulation § 1.817-5(f)(2)(i)(A), the provisions of which require that all of the beneficial interests in the RIC be held by one or more insurance company segregated asset accounts to be eligible for look-through treatment. |
| 200344002(PDF, 25K) |
10/31/2003 |
| Requested rulings pursuant to Treasury Regulation § 1.1502-75 and 1.1502-47. |
| 200344001(PDF, 35K) |
10/31/2003 |
| Requested rulings under § 355 of the Internal Revenue Code. |
| 200343030(PDF, 630K) |
7/31/2003 |
| Request for letter rulings under § 401(a)(9) and 408(d)(3) of the Internal Revenue Code submitted on your behalf by your authorized representative. |
| 200343029(PDF, 336K) |
7/29/2003 |
| Request a private letter ruling under § 408(d) (3) of the Internal Revenue Code. |
| 200343028(PDF, 1.0M) |
7/30/2003 |
| Requesting rulings under § 4942, 4943, 4944,4945, and 501 (c)(3) of the Internal Revenue Code. |
| 200343027(PDF, 1.0M) |
7/30/2003 |
| Requesting rulings under § 4942, 4943, 4944,4945, and 501 (c)(3) of the Internal Revenue Code. |
| 200343026(PDF, 356K) |
7/29/2003 |
| Ruling request concerning the effect of a proposed transaction on your exempt status under § 501 (c)(3) of the Internal Revenue Code, and the application of private foundation § 507 and 4941 of the Code. |
| 200343025(PDF, 74K) |
10/24/2003 |
| Issues: (1) Does Notice 95-50, 1995-2 C.B. 333, affect the requirement of § 1.274-5(c) that a taxpayer maintain adequate records in order to claim a deduction for travel expenses under § 274? (2) What amount may a taxpayer claim for incidental expenses incurred while traveling on a ship in the middle of the ocean? |
| 200343024(PDF, 59K) |
10/24/2003 |
| Requesting that the Service grant relief under § 1362(f) of the Internal Revenue Code for inadvertent termination of an S corporation election and an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 1361(d)(2). |
| 200343023(PDF, 49K) |
10/24/2003 |
| Requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat Sub as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200343022(PDF, 48K) |
10/24/2003 |
| Requesting a ruling that Partnership be granted relief under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations for an extension of time in which to make such an election under § 754 of the Internal Revenue Code. |
| 200343021(PDF, 47K) |
10/24/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election to be classified as an association taxable as a corporation for federal tax purposes effective d1. |
| 200343020(PDF, 44K) |
10/24/2003 |
| Requested relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200343019(PDF, 52K) |
10/24/2003 |
| Requesting a ruling under § 2642 of the Internal Revenue Code. |
| 200343018(PDF, 60K) |
10/24/2003 |
| Requested rulings on behalf of the Taxpayer concerning 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 an allocation of the Taxpayer’s generation-skipping transfer exemption to a transfer to an irrevocable trust, and the GST tax consequences of the severance of the trust pursuant to § 2642(a)(3) into two separate trusts. |
| 200343017(PDF, 62K) |
10/24/2003 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. Taxpayer is requesting this schedule because Commission A, in Order, decreased the amount of decommissioning costs to be included in cost of service for Plant. |
| 200343016(PDF, 61K) |
10/24/2003 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. Taxpayer is requesting this schedule because Commission A, in Order, decreased the amount of decommissioning costs to be included in cost of service for Plant. |
| 200343015(PDF, 60K) |
10/24/2003 |
| Requested rulings on behalf of the Taxpayer concerning 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 an allocation of the Taxpayer’s generation-skipping transfer exemption to a transfer to an irrevocable trust, and the GST tax consequences of the severance of the trust pursuant to § 2642(a)(3) into two separate trusts. |
| 200343014(PDF, 56K) |
10/24/2003 |
| 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 generation-skipping transfer exemption. |
| 200343013(PDF, 46K) |
10/24/2003 |
| Requesting permission for Taxpayer and its § 41(f)(5) controlled group to revoke their election under § 41(c)(4) of the Internal Revenue Code for the taxable year ending on Date 5. |
| 200343012(PDF, 51K) |
10/24/2003 |
| Requesting a ruling that a proposed change in Company’s operating structure will not affect a previously issued private letter ruling that rental income received by Company from certain properties, both directly and through various partnerships, was not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200343011(PDF, 49K) |
10/24/2003 |
| Requesting a ruling that X's rental income from its commercial and residential rental properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200343010(PDF, 45K) |
10/24/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200343009(PDF, 51K) |
10/24/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code that Company's S corporation election was inadvertently invalid. |
| 200343008(PDF, 60K) |
10/24/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200343007(PDF, 53K) |
10/24/2003 |
| 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 A. |
| 200343006(PDF, 49K) |
10/24/2003 |
| Requesting a ruling on the tax consequences of Employer’s deferred compensation plan. |
| 200343005(PDF, 45K) |
10/24/2003 |
| Request that we supplement our letter ruling PLR-116429-98 (Original Letter Ruling) and supplemental letter rulings PLR-105017-99 (First Supplemental Letter Ruling) and PLR-147187-01 (Second Supplemental Letter Ruling). |
| 200343004(PDF, 56K) |
10/24/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200343003(PDF, 56K) |
10/24/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200343002(PDF, 70K) |
10/24/2003 |
| Issue: Whether amounts earned by Corporation during the six month period after Decedent’s death that were not distributed to the Decedent’s estate as the sole shareholder during that period are “excluded property” for purposes of determining the value of the stock of Corporation included in Decedent’s gross estate under § 2032 of the Internal Revenue Code. |
| 200343001(PDF, 46K) |
10/24/2003 |
| Issues: (1) Are the amounts paid to Taxpayer with respect to services provided by Taxpayer subject to the tax on communications services under § 4251 of the Internal Revenue Code? (2) If so, is Taxpayer responsible for collecting the tax and paying it over to the government? |
| 200342009(PDF, 460K) |
7/23/2003 |
| Ruling request concerning the federal income tax treatment, under § 414(h)(2) of the Internal Revenue Code, of certain contributions to Plan X. |
| 200342008(PDF, 767K) |
7/21/2003 |
| Request for rulings, as amended, under § 507,4941, and 4945 of the Internal, Revenue Code, arising from your private foundation's reorganization and its proposed payments of liabilities, as allowed by a court and described below. |
| 200342007(PDF, 621K) |
7/23/2003 |
| Request a letter ruling under § 401(a)(13) of the Internal Revenue Code with respect to a proposed transaction described herein. |
| 200342006(PDF, 296K) |
7/21/2003 |
| This letter constitutes notice that the conditional waiver has been granted in accordance with § 412(d) of the Internal Revenue Code and § 303 of the Employee Retirement Income Security Act of 1974 (ERISA). |
| 200342005(PDF, 235K) |
7/22/2003 |
| Request for a waiver of the minimum funding standard for the plan year beginning January 1, 2001, for the above-referenced plan, and April 17, 2003, for waivers of the 10 percent and 100 percent excise taxes on the uncorrected funding deficiency. |
| 200342004(PDF, 67K) |
10/17/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200342003(PDF, 65K) |
10/17/2003 |
| Requesting a ruling that the exchange of a portion of a variable annuity contract (Annuity Contract 1) for a deferred annuity contract (Annuity Contract 2) qualifies for tax-free exchange treatment under § 1035 of the Internal Revenue Code. Taxpayer also seeks a ruling on the proper allocation of basis between the contracts. |
| 200342002(PDF, 48K) |
10/17/2003 |
| Requesting that the Service grant X 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. |
| 200342001(PDF, 56K) |
10/17/2003 |
| Requesting an extension of time under § 2642(g) of the Internal Revenue Code and § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Grantor’s generation-skipping transfer tax exemption. |
| 200341024(PDF, 648K) |
7/18/2003 |
| Requested certain rulings under § 4945 of the Internal Revenue Code and § 53.4945-4(a) of the Foundation and Similar Excise Taxes Regulations. |
| 200341023(PDF, 545K) |
7/18/2003 |
| Requested ruling concerning § 403(b) and 7701 of the Internal Revenue Code. |
| 200341022(PDF, 172K) |
7/15/2003 |
| Request for a waiver of the minimum funding standard for the plan year beginning October 1, 2000, for the above-referenced plan, and June 6, 2003, for waivers of the 10 percent and I00 percent excise taxes on the uncorrected funding deficiency. |
| 200341021(PDF, 56K) |
7/15/2003 |
| This letter constitutes notice that the request of made by your authorized representative for a modification of condition 1 of our ruling letter of, is granted. Condition 1 requires that the Company will provide the Plan with security in a manner satisfactory to the Pension Benefit Guaranty Corporation (PBGC) for the sum of the required quarterly contributions under § 412(m)(4) of the Code that are due. |
| 200341020(PDF, 56K) |
7/15/2003 |
| This letter constitutes notice that the request of made by your authorized representative for a modification of condition 1 of our ruling letter of, is granted. Condition 1 requires that the Company will provide the Plan with security in a manner satisfactory to the Pension Benefit Guaranty Corporation (PBGC) for the sum of the required quarterly contributions under § 412(m)(4) of the Code that are due. |
| 200341019(PDF, 56K) |
10/10/2003 |
| Requesting a ruling that certain reserves held by a foreign subsidiary for life insurance contracts required to be set forth on the financial statements and filed with the life insurance regulator 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. |
| 200341018(PDF, 45K) |
10/10/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200341017(PDF, 49K) |
10/10/2003 |
| Requested ruling: whether Coop may utilize its patronage sourced loss by canceling an equal amount of currently outstanding qualified notices of allocation. And whether Coop will recognize any taxable income upon the cancellation of such patronage equity. |
| 200341016(PDF, 15K) |
10/10/2003 |
| Requesting a generation-skipping transfer tax ruling under § 2632 of the Internal Revenue Code. |
| 200341015(PDF, 11K) |
10/10/2003 |
| Request an extension of time to file an election under § 855(a) of the Internal Revenue Code. |
| 200341014(PDF, 13K) |
10/10/2003 |
| Requests a ruling that it will not recognize gain or loss under § 852(b)(6) of the Internal Revenue Code of 1986 upon the distribution of stock or other securities in redemption of shares of Fund upon the request of a shareholder pursuant to a tender offer. |
| 200341013(PDF, 14K) |
10/10/2003 |
| Requesting a generation-skipping transfer tax ruling under § 2632 of the Internal Revenue Code. |
| 200341012(PDF, 55K) |
10/10/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for Owner to elect to treat Company as an entity that is disregarded from Owner under § 301.7701-3. |
| 200341011(PDF, 16K) |
10/10/2003 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of proposed modifications to a trust. |
| 200341010(PDF, 7K) |
10/10/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200341009(PDF, 13K) |
10/10/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200341008(PDF, 9K) |
10/10/2003 |
| Requested that the Internal Revenue Service determine whether tax is imposed by § 4064 of the Internal Revenue Code on the sale of by the Taxpayer. |
| 200341007(PDF, 7K) |
10/10/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200341006(PDF, 59K) |
10/10/2003 |
| Requesting rulings under § 301.9100-3 of the Procedure and Administration Regulations as well as rulings under § 2632 and § 2652 of the Internal Revenue Code. |
| 200341005(PDF, 51K) |
10/10/2003 |
| Issues: 1) Whether the conveyance by Shareholder of e shares of Corporation A common stock to Trust, through Partnership, constitutes a taxable sale or exchange of the Corporation A common stock by Shareholder for federal income tax purposes. (2) Whether the sale of the Financial Instruments to third-party investors constitutes a bona fide sale of the Corporation A common stock for federal income tax purposes. (3) Whether the contributions by Shareholder of c and d shares of Corporation A common stock to Partnership on the Execution Date and the Option Date, respectively, and Partnership’s subsequent distributions to Shareholder of $t and $u on the Execution Date and the Option Date, respectively, are disguised sales under § 707(a)(2)(B) of the Internal Revenue Code? (4) In what manner should the parties treat the following transfers of cash for tax purposes: (A) $q from Trust to Partnership? (B) $s from Partnership to Shareholder? |
| 200341004(PDF, 74K) |
10/10/2003 |
| Issue: Whether liability for cover damages, damages for lost profits, inventory carrying costs, and other miscellaneous costs arising out of the breach of contracts for the sale of goods qualify as product liability within the meaning of § 172(f)(4). |
| 200341003(PDF, 82K) |
10/10/2003 |
| Issues: (1) When Taxpayer makes first retail sales of the vehicles described below, is it liable for the excise tax imposed by § 4051(a)(1) of the Internal Revenue Code on truck tractors, or are the vehicles classified as trucks upon which no tax is imposed by virtue of § 4051(a)(2). (2) If the IRS rules that the described vehicles are taxable tractors, will the IRS grant Taxpayer's request to apply this technical advice memorandum (TAM) on a nonretroactive basis under § 7805(b)(8)? |
| 200341002(PDF, 38K) |
10/10/2003 |
| Issues: (1) Do the transfers to Trust subject to the charities’ withdrawal power qualify for the gift tax charitable deduction under § 2522 of the Internal Revenue Code? (2) Alternatively, do the transfers to Trust subject to the charities’ withdrawal power qualify for the gift tax annual exclusion under § 2503(b)? (3) How are those transfers treated in computing adjusted taxable gifts under § 2001(b)? |
| 200341001(PDF, 21K) |
10/10/2003 |
| Request an extension of time under Treasury Regulation § 301.9100-3 to request a ruling under § 1.884-2T(d)(5)(ii) that the transfer in Year X is not a disposition for purposes of § 1.884-2T(d)(5)(i). |
| 200340030(PDF, 576K) |
7/9/2003 |
| Requested ruling concerning the status of certain securities held by Plan X under § 402(e)(4) of the Internal Revenue Code. |
| 200340029(PDF, 170K) |
7/9/2003 |
| 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 April 30, 2003. |
| 200340028(PDF, 193K) |
7/9/2003 |
| 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. |
| 200340027(PDF, 163K) |
7/10/2003 |
| 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 April 30, 2003. |
| 200340026(PDF, 343K) |
7/8/2003 |
| Requesting advance approval of your grant-making procedures under § 4945(g) of the Internal Revenue Code. |
| 200340025(PDF, 1.0M) |
7/11/2003 |
| Ruling request concerning certain employee elections regarding System Y and the pick up of certain employee contributions to System Y under § 414(h)(2) of the Internal Revenue Code. |
| 200340024(PDF, 27K) |
10/3/2003 |
| Requesting certain rulings under § 752 and 465 of the Internal Revenue Code regarding P's proposal to Issue: unsecured debt to refinance certain outstanding debt obligations. |
| 200340023(PDF, 8K) |
10/3/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200340022(PDF, 26K) |
10/3/2003 |
| Requesting the following rulings regarding the proposed division of the Trust into Trust A and Trust B: (1) It will not cause the Trust, Trust A, or Trust B to fail to qualify as a charitable remainder trust under § 664 of the Internal Revenue Code. (2) The division of the community property interest of A and B in the Trust into Trust A and Trust B will not be subject to gift tax as to A or B, because the division is a transfer of property pursuant to a divorce under § 2516. (3) Trust A and Trust B will not be treated as newly created organizations. The aggregate tax benefits of the Trust under § 507(d) will carry over to Trust A and Trust B in proportion to the amount of the Trust’s assets transferred to Trust A and Trust B, subject to any liability the Trust has under Chapter 42 of the Code to the extent not already satisfied by the Trust. (4) The division of the Trust pursuant to divorce into Trust A and Trust B will not result in taxable income to A or B pursuant to § 1041 (5) If reasonable in amount, payment from Trust assets of legal fees and other expenditures incurred by the Trust to effect the division of the Trust will not constitute an act of self-dealing under § 4941, or constitute taxable expenditures under § 4945. |
| 200340021(PDF, 13K) |
10/3/2003 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Donor’s generation-skipping transfer exemption. |
| 200340020(PDF, 13K) |
10/3/2003 |
| Requested ruling under § 1362(f) of the Internal Revenue Code. |
| 200340019(PDF, 10K) |
10/3/2003 |
| Requested ruling on behalf of Taxpayer regarding the basis of certain real estate acquired by Taxpayer from her mother’s estate through the exercise of an option. |
| 200340018(PDF, 9K) |
10/3/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect to be treated as an association taxable as a corporation for federal tax purposes. |
| 200340017(PDF, 9K) |
10/3/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect to be treated as an association taxable as a corporation for federal tax purposes. |
| 200340016(PDF, 21K) |
10/3/2003 |
| Requests 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 loss incurred by Entity A and the dual consolidated loss incurred by Entity B in the tax year ended on Date 1. |
| 200340015(PDF, 33K) |
10/3/2003 |
| Requested rulings concerning certain additions to Trust and the proposed division of Trust. |
| 200340014(PDF, 9K) |
10/3/2003 |
| Requested ruling under §301.9100 of the Procedure and Administration Regulations. |
| 200340013(PDF, 16K) |
10/3/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of generation-skipping transfer tax exemption. |
| 200340012(PDF, 57K) |
10/3/2003 |
| Requested rulings concerning whether Decedent's interests in certain real estate qualify as an interest in a closely held business for purposes of § 6166 of the Internal Revenue Code |
| 200340011(PDF, 60K) |
10/3/2003 |
| Requested rulings that (1) certain extended service contracts issued by Taxpayer are insurance contracts for Federal income tax purposes, and (2) that Taxpayer will qualify as an insurance company taxable under § 831 of the Internal Revenue Code. |
| 200340010(PDF, 45K) |
10/3/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200340009(PDF, 50K) |
10/3/2003 |
| Requested ruling that D be granted an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200340008(PDF, 50K) |
10/3/2003 |
| Requested ruling that F be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200340007(PDF, 70K) |
10/3/2003 |
| Request for rulings that (a) S1, a subsidiary of the Holding Company, is a successor in interest to Electric Company for purposes of § 142(f)(3)(B) of the Internal Revenue Code of 1986 and (b) the Facilities, as described below, will serve or are available on a regular basis for general public use within the meaning of § 1.103-8(a)(2) and § 1.103-8(f)(1) of the Income Tax Regulations. |
| 200340006(PDF, 70K) |
10/3/2003 |
| Request on behalf of the Issuer and the Holding Company for rulings that (a) S1, a subsidiary of the Holding Company, is a successor in interest to Electric Company for purposes of § 142(f)(3)(B) of the Internal Revenue Code of 1986 and (b) the Facilities, as described below, will serve or are available on a regular basis for general public use within the meaning of § 1.103-8(a)(2) and § 1.103-8(f)(1) of the Income Tax Regulations. |
| 200340005(PDF, 58K) |
10/3/2003 |
| Requested ruling that redemption of the Project’s tax-exempt financing at any time on or after the date on which the Project is placed in service for purposes of § 42 of the Internal Revenue Code will not preclude a determination that the Project was financed by tax-exempt bonds for purposes of § 42(h)(4)(B). |
| 200340004(PDF, 79K) |
10/3/2003 |
| Request for a letter ruling regarding the reporting obligation of the Fund with respect to the payments to class counsel made pursuant to a settlement agreement and court order regarding attorneys’ fees. |
| 200340003(PDF, 46K) |
10/3/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200340002(PDF, 44K) |
10/3/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200340001(PDF, 57K) |
10/3/2003 |
| Requested rulings on behalf of Decedent’s estate concerning the estate tax consequences under § 2055 of the Internal Revenue Code and the income tax consequences under § 664 of a proposed reformation of a split-interest charitable trust. |
