| 200349009(PDF, 692K) |
9/9/2003 |
| Request for letter rulings under § 408(d)(3) of the Internal Revenue Code. |
| 200349008(PDF, 677K) |
9/9/2003 |
| Requesting a series of rulings on your behalf regarding the tax consequences associated with the transactions described below. |
| 200349007(PDF, 260K) |
9/10/2003 |
| Requesting advance approval of your grant-making procedures under § 4945(g) of the Internal Revenue Code. |
| 200349006(PDF, 284K) |
9/10/2003 |
| Request for a waiver of the minimum funding standard for the above-named pension plan for the plan year ending November 30,2002. |
| 200349005(PDF, 834K) |
9/9/2003 |
| Request to retroactively amend the above-named money purchase pension plan under § 412(c)(8) of the Internal Revenue Code and § 302(c)(8) of the Employee Retirement Income Security Act of 1974 (ERISA), for approval of the plan amendment adopted on June 26, 2002. |
| 200349004(PDF, 207K) |
9/9/2003 |
| Request for a waiver of the minimum funding standard for the above-named pension plan for the plan year ending December 28,2002. |
| 200349003(PDF, 167K) |
9/9/2003 |
| Request for a waiver of the minimum funding standard for the above-named pension plan for the plan year ending December 31,2002. |
| 200349002(PDF, 317K) |
9/8/2003 |
| Request for a waiver of the minimum funding standard for the above-named pension plan for the plan year ending September 30,2002. |
| 200349001(PDF, 67K) |
12/5/2003 |
| Request for a ruling concerning whether charges for installation, warranty, and transportation are excludable from the taxable sales price of certain truck bodies that are subject to the retail excise tax imposed by § 4051 of the Internal Revenue Code. |
| 200348031(PDF, 926K) |
9/5/2003 |
| Requested ruling with respect to the federal income tax treatment of certain contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200348030(PDF, 846K) |
9/4/2003 |
| Requested a ruling on our behalf concerning the status of Plan X under § 414(e) of the Internal Revenue Code. |
| 200348029(PDF, 641K) |
9/2/2003 |
| You request rulings under § 501 (c)(3), 509 and 511 through 514 of the Internal Revenue Code. |
| 200348028(PDF, 47K) |
11/28/2003 |
| Requesting a ruling on the federal income tax consequences of the Employer’s deferred compensation plan. |
| 200348027(PDF, 45K) |
11/28/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200348026(PDF, 47K) |
11/28/2003 |
| 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. |
| 200348025(PDF, 53K) |
11/28/2003 |
| 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)-1T(c) of the Income Tax Regulations with respect to Purchaser’s acquisition of the stock of Target, on Date B. |
| 200348024(PDF, 45K) |
11/28/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200348023(PDF, 75K) |
11/28/2003 |
| Requesting a letter ruling concerning whether the payments made by Generator to Corp 3, which, in turn, reimbursed Taxpayer for the cost of a high-voltage electric interconnection, will be excluded from Taxpayer’s gross income as a contribution to the capital of Taxpayer under § 118(a) of the Internal Revenue Code, and will not be treated as a contribution in aid of construction to Taxpayer under § 118(b). |
| 200348022(PDF, 53K) |
11/28/2003 |
| Requesting an extension of time under § 301.9100-3 of Procedure and Administration Regulations to file an election. The extension is being requested in order to allow Parent and Foreign Subs to file an election to restore value under § 1.382-8(h) of the Income Tax Regulations. |
| 200348021(PDF, 45K) |
11/28/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200348020(PDF, 55K) |
11/28/2003 |
| Requesting a ruling under § 301 and 305. |
| 200348019(PDF, 47K) |
11/28/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200348018(PDF, 54K) |
11/28/2003 |
| Requesting an extension of time pursuant to § 301.9100-1 of the Procedure and Administration Regulations to post a surety bond under § 42(j)(6) of the Internal Revenue Code in order to avoid recapture of the low-income housing credit under § 42(a). |
| 200348017(PDF, 54K) |
11/28/2003 |
| Requesting an extension of time pursuant to § 301.9100-1 of the Procedure and Administration Regulations to post a surety bond under § 42(j)(6) of the Internal Revenue Code in order to avoid recapture of the low-income housing credit under § 42(a). |
| 200348016(PDF, 47K) |
11/28/2003 |
| Requesting an extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200348015(PDF, 45K) |
11/28/2003 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200348014(PDF, 49K) |
11/23/2003 |
| Requesting relief under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations for an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200348013(PDF, 44K) |
11/28/2003 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200348012(PDF, 66K) |
11/28/2003 |
| Request for rulings under § 280G and 4999 of the Internal Revenue Code. Specifically, the letter concerns whether the split-off/spin-off transaction and merger transaction, both of which are described below, cause a change in ownership or effective control of, or a change in a substantial portion of assets of, Corporation 1, in the case of the split-off/spin-off transaction, or of Corporation 2 in the case of the merger transaction. |
| 200348011(PDF, 63K) |
11/28/2003 |
| Requested a ruling on the Federal gift tax consequences of a proposed disclaimer of an interest in a trust. |
| 200348010(PDF, 48K) |
11/28/2003 |
| Requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make an alternate valuation election under § 2032 of the Internal Revenue Code. |
| 200348009(PDF, 57K) |
11/28/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code on behalf of X and an extension of time under § 301.9100-03 of the Procedure and Administration Regulations to make an Electing Small Business Trust (ESBT) election for Trust1. |
| 200348008(PDF, 47K) |
11/28/2003 |
| Requesting an extension of time for Company to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be treated as a disregarded entity. Company represents the following facts. |
| 200348007(PDF, 49K) |
11/28/2003 |
| 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. |
| 200348006(PDF, 62K) |
11/28/2003 |
| Request a ruling on the application of § 2703 of the Internal Revenue Code to the proposed transaction. |
| 200348005(PDF, 57K) |
11/28/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer tax exemption. |
| 200348004(PDF, 97K) |
11/28/2003 |
| Issues: (1) Whether taxpayer’s method of accounting for the Advance Payment Transactions results in a material distortion of income under Internal Revenue Code § 925(a) and Temporary Treasury Regulation § 1.925(a)-1T(c)(6)(iii)(B). (2) Whether the reimbursement payment claimed by taxpayer is a correct application of the “no loss” rule under Temp. Treas. Reg. § 1.925(a)-1T(e)(1)(i). |
| 200348003(PDF, 22K) |
11/28/2003 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to file the following: (a) an election and agreement under § 1.1503-2(g)(2)(i) with respect to the dual consolidated losses incurred by Entity A in the tax year ended on Date 1; (b) elections and agreements under § 1.1503-2(g)(2(i) with respect to the dual consolidated losses incurred by Entity B in the tax years ended on Dates 1 and 2; and (c) an annual certification under § 1.1503-2(g)(2)(vi) for the tax year ended on Date 2 with respect to the dual consolidated losses incurred by Entity B in the tax year ended on Date 1. |
| 200348002(PDF, 17K) |
11/28/2003 |
| Letter Ruling Request Regarding A Deduction For State Income Taxes; concerning the application of § 164 of the Internal Revenue Code to state income taxes offset by purchased state tax credits. |
| 200348001(PDF, 29K) |
11/28/2003 |
| 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. |
| 200347025(PDF, 52K) |
11/21/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200347024(PDF, 66K) |
11/21/2003 |
| Issues: (1) What property constitutes the facility under § 29 for the purpose of determining when a facility that produces solid synthetic fuel from coal is placed into service? (2) If a facility has been placed in service timely, how will the relocation of all or a portion of that facility affect its qualification for the credit under § 29? (3) If a portion of a facility that has been placed in service timely is moved, how is that portion to be valued in order to determine whether the relocated facility is newly placed in service? |
| 200347023(PDF, 207K) |
7/17/2003 |
| Issues: (1) Should the initial excise taxes due under § 4942 of undistributed income for the years ending December 31, be abated under § 4962? the Internal Revenue Code on X's 1988 through December 31, 1992 (2) Should the initial excise taxes due under § 4943 on X's excess business holdings for the years ending December 31, 1988 through December 31, 1997 be abated under § 4962? (3) Should the initial excise taxes due under § 4944 on X's jeopardizing investment for the years ending December 31,1988 through December 31, 1997 be abated under § 4962? (4) Should the initial excise tax due under § 4945 on X's taxable expenditures for the year ending December 31, 1988 be abated under § 4962? |
| 200347022(PDF, 476K) |
8/26/2003 |
| Ruling request concerning the federal income tax treatment under § 41 4(h)(2) of the Internal Revenue Code, of certain contributions to Plan X. |
| 200347021(PDF, 505K) |
8/27/2003 |
| Ruling request, wherein M requests approval of a proposed set-aside of funds, to be treated as qualifying distributions under § 4942(g)(2) of the Internal Revenue Code, for its taxable year ending June 30, 2003. |
| 200347020(PDF, 810K) |
8/28/2003 |
| Ruling request concerning the pick up of certain employee contributions to Plan X under § 414(h)(2) of the Internal Revenue Code, and the federal income tax treatment of certain transfers of funds from Plan Y to Plan X. |
| 200347019(PDF, 130K) |
8/28/2003 |
| Ruling request concerning whether Agency A may establish a plan described in § 401(k) of the Internal Revenue Code for the benefit of Group B Members who are employees of Agency A. |
| 200347018(PDF, 531K) |
8/28/2003 |
| Ruling request, wherein M requests approval of a proposed set-aside of funds, to be treated as qualifying distributions under § 4942(g)(2) of the Internal Revenue Code, for its taxable year ending June 30, 2003. |
| 200347017(PDF, 993K) |
8/29/2003 |
| Requesting a ruling concerning your proposed distribution to a for profit corporation for the restricted purpose of providing medical malpractice reinsurance to ensure the availability of medical care in a specific state. |
| 200347016(PDF, 57K) |
11/21/2003 |
| Requesting a ruling on whether the Debt is a qualifying debt instrument for purposes of § 1.1275-6 of the Income Tax Regulations. |
| 200347015(PDF, 52K) |
11/21/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200347014(PDF, 95K) |
11/21/2003 |
| Issue: Are certain gain proceeds from the sale of Assets excludible by Taxpayer from gross income. |
| 200347013(PDF, 47K) |
11/21/2003 |
| Requesting a supplement to our letter ruling PLR-101241-00 (the “Prior Letter Ruling”). |
| 200347012(PDF, 53K) |
11/21/2003 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200347011(PDF, 56K) |
11/21/2003 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of a proposed modification of a trust. |
| 200347010(PDF, 54K) |
11/21/2003 |
| Request on behalf of the Fund concerning whether work-related disability benefits paid by the Fund are excludable from the gross income of recipients under § 104(a)(1) of the Internal Revenue Code. |
| 200347009(PDF, 70K) |
11/21/2003 |
| Request for the following three rulings: (1) the License Agreement described below will not cause the Series A and Series B Bonds (collectively, “the Bonds”) to satisfy the private business use test under § 145(a)(2)(B) and 141(b)(1) of the Internal Revenue Code; (2) the Scientist Agreement described below will not cause the Bonds to satisfy the private business use test under § 145(a)(2)(B) and 141(b)(1); (3) the right of the Large Contributors described below to require the Organization to transfer shares of the Corporation’s Class A Stock to one or more § 501(c)(3) organizations chosen by the Large Contributors will not cause the Bonds to satisfy the private business use test under § 145(a)(2)(B) and 141(b)(1). |
| 200347008(PDF, 51K) |
11/21/2003 |
| Requesting rulings under § 355 of the Internal Revenue Code with respect to a proposed transaction. |
| 200347007(PDF, 52K) |
11/21/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200347006(PDF, 52K) |
11/21/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200347005(PDF, 52K) |
11/21/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200347004(PDF, 42K) |
11/21/2003 |
| Issues: (1) Whether respite care payments made to third parties for purposes of providing relief to foster care providers are excludable from gross income under § 131. (2) Whether a respite care provider is an independent contractor or a common law employee. (3) Whether the governmental agency that pays for the respite care is the § 3401(d) employer. (4) Whether the governmental agency, as the § 3401(d)(1) employer, may file one Form 941 and/or Form 940 for employment tax reporting purposes. |
| 200347003(PDF, 36K) |
11/21/2003 |
| Request for a ruling concerning whether Employer's parking payment plan meets the requirements of a qualified transportation fringe under § 132(f) of the Internal Revenue Code. If the Plan meets these requirements, reimbursements made by the Employer to employees for parking pursuant to the Plan are excluded from the employee’s gross income, and are not subject to income tax withholding, Federal Insurance Contributions Act (FICA) tax, or Federal Unemployment Tax Act (FUTA) tax. |
| 200347002(PDF, 24K) |
11/21/2003 |
| Requested a private letter ruling on behalf of Corp A that Corp B and its pre-acquisition subsidiaries be permitted to change to the tax book value method of asset valuation for purposes of apportioning interest expense for the portion of Corp A’s tax year that begins on Date 2, and for subsequent tax years. |
| 200347001(PDF, 45K) |
11/21/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200346032(PDF, 539K) |
8/19/2003 |
| Request relief under § 301.9100-3 of the Procedure and Administration Regulations |
| 200346031(PDF, 307K) |
8/19/2003 |
| Request for waiver of the minimum funding standard for above-named pension plan for the plan year beginning December 1, 2001. |
| 200346030(PDF, 302K) |
8/19/2003 |
| Request for waiver of the minimum funding standard for above-named pension plan for the plan year beginning December 1, 2001. |
| 200346029(PDF, 302K) |
8/19/2003 |
| Request for waiver of the minimum funding standard for above-named pension plan for the plan year beginning December 1, 2001. |
| 200346028(PDF, 193K) |
8/18/2003 |
| Request for waiver of the minimum funding standard for above-named pension plan for the plan year beginning January 1,2002. |
| 200346027(PDF, 306K) |
8/19/2003 |
| Request for waiver of the minimum funding standard for above-named pension plan for the plan year beginning December 1, 2001. |
| 200346026(PDF, 640K) |
8/21/2003 |
| Requested a ruling on behalf of the Trustees of the above-named pension plan regarding the application of g 41 3(b)(7) of the Internal Revenue Code in determining the deductibility of contributions made to the Plan for the plan year ending on December 31, 2001. |
| 200346025(PDF, 488K) |
8/21/2003 |
| Ruling request dated Date 1 submitted on your behalf by your authorized representative under § 408(d)(3) of the Internal Revenue Code. |
| 200346024(PDF, 552K) |
8/20/2003 |
| Requested a ruling on behalf of Corporation A with respect to deductibility of contributions under § 404(a)(7) of the Internal Revenue Code. |
| 200346023(PDF, 29K) |
11/14/2003 |
| Request for a ruling that the transfer by Corp V of the shares of Corp W to Corp Y will not be treated as a “disposition” triggering the imposition of tax under Treasury Regulation § 1.884-2T(d)(5), provided Corp V and Corp Y agree to be bound by the statements attached to their 2000 tax returns, as amended. |
| 200346022(PDF, 45K) |
11/14/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200346021(PDF, 45K) |
11/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200346020(PDF, 67K) |
11/14/2003 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(2) of the Income Tax Regulations. |
| 200346019(PDF, 101K) |
11/14/2003 |
| Request for rulings dated January 15, 2003, submitted by your authorized representative on behalf of the Master Fund and the Feeder Fund. |
| 200346018(PDF, 55K) |
11/14/2003 |
| Requesting an extension of time under § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Taxpayer’s generation-skipping transfer exemption. |
| 200346017(PDF, 63K) |
11/14/2003 |
| Requesting rulings on certain federal income tax consequences of a proposed transaction. |
| 200346016(PDF, 53K) |
11/14/2003 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200346015(PDF, 48K) |
11/14/2003 |
| Requested to permit Taxpayer A and Taxpayer B to reelect the foreign earned income exclusion pursuant to § 911 of the Internal Revenue Code |
| 200346014(PDF, 46K) |
11/14/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200346013(PDF, 71K) |
11/14/2003 |
| Requesting rulings as to the federal income tax consequences of a proposed transaction. |
| 200346012(PDF, 55K) |
11/14/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200346011(PDF, 53K) |
11/14/2003 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser and Seller are requesting an extension to file a “§ 338(h)(10) election” under § 338(g) and 338(h)(10) of the Internal Revenue Code and § 1.338(h)(10)-1T(c) of the Income Tax Regulations with respect to Purchaser’s acquisition of the stock of Target, on Date B. |
| 200346010(PDF, 48K) |
11/14/2003 |
| 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 US taxes under subtitle A or subtitle B of the Code. |
| 200346009(PDF, 48K) |
11/14/2003 |
| 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 US taxes under subtitle A or subtitle B of the Code. |
| 200346008(PDF, 73K) |
11/14/2003 |
| letter submitted by your authorized representative on your behalf, and subsequent correspondence, concerning the generation-skipping transfer tax status of Trusts 1-3.concerning the generation-skipping transfer tax status of Trusts 1-3. |
| 200346007(PDF, 153K) |
11/14/2003 |
| Issues: (1) Should the form of the sale/leaseback transaction entered into by Taxpayer be respected for federal income tax purposes, or should it be recharacterized as a financing arrangement? (2) If the form of the sale/leaseback transaction is not re-characterized as a financing arrangement, does the Taxpayer's amount realized on the sale of the Facility include the fair market value of the Taxpayer's leasehold interest in the Facility, which purportedly allows Taxpayer to lease the property at less than fair rental value? (3) If the form of the sale/leaseback transaction is not re-characterized as a financing arrangement, is the sale/leaseback a like-kind exchange and, consequently, a transaction for which no gain or loss should be recognized under § 1031? |
| 200346006(PDF, 33K) |
11/14/2003 |
| Issue: You have requested advice on an issue pertaining to the determination of the collection statute expiration date (CSED) in cases of back-to-back bankruptcy filings. The issue presented is whether any time should be added to the CSED in a situation where a second bankruptcy petition is filed less than six months after the automatic stay terminated in the first bankruptcy. Under Internal Revenue Code § 6503(h)(2), the running of the collection statute is suspended during bankruptcy and for six months after termination of the automatic stay. You ask whether the Service, in addition to being entitled to the sixmonth suspension arising from the second bankruptcy, is entitled to a suspension representing the “unused” portion of the six-month period attributable to the first bankruptcy. |
| 200346005(PDF, 40K) |
11/14/2003 |
| Issue: Whether the sale of national defense weaponry, military systems, and similar equipment -- that qualifies as export property under § 927(a) of the foreign sales corporation (“FSC”) provisions -- for use by the United States or any instrumentality thereof (the “US government”) violates § 924(f)(1)(A)(ii). |
| 200346004(PDF, 20K) |
11/14/2003 |
| Requests a ruling letter to supplement PLR-128563-01, which granted Taxpayer an extension of time under Treasury Regulation § 301.9100-3 to file the following: (1) agreements pursuant to § 1.1503-2A(c)(3)(ii); (2) agreements pursuant to § 1.1503-2(g)(2)(i); (3) annual certifications pursuant to § 1.1503-2A(c)(3)(v); (4) annual certifications pursuant to § 1.1503-2(g)(2)(vi)(B), and (5) agreements pursuant to § 1.1503-2(g)(2)(iv)(B)(2)(iii). These filings were to be made in accordance with Schedule A that was attached to PLR-128563-01. |
| 200346003(PDF, 24K) |
11/14/2003 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to file agreements under § 1.1503-2(g)(2)(i) as required under § 1.1503-2(g)(2)(iv)(B)(2)(iii) for the tax year ended on Date One in accordance with Schedule A, which is attached and made a part of this ruling letter. |
| 200346002(PDF, 36K) |
11/14/2003 |
| Request for a letter ruling made by your organization’s attorney. Your attorney requested a ruling on behalf of Y that Y is an instrumentality of State V within the meaning of Internal Revenue Code § 3121(b)(7)(F), and consequently is not required to withhold or pay Old Age, Survivors, and Disability Insurance tax under Code § 3101(a) and 3111(a). |
| 200346001(PDF, 33K) |
11/14/2003 |
| Requested rulings as to the federal income tax consequences of a proposed transaction. |
| 200345050(PDF, 72K) |
11/7/2003 |
| Requesting rulings on certain Federal income tax consequences of a proposed and partially consummated transaction. |
| 200345049(PDF, 126K) |
11/7/2003 |
| Request for rulings on certain federal income tax consequences of a proposed and partially completed transaction. |
| 200345048(PDF, 207K) |
8/13/2003 |
| This letter constitutes notice that a 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. The amount for which the conditional waiver has been granted is the contribution that would otherwise be required to reduce the balance in the funding standard account of the plan to zero as of the end of the plan year for which the waiver has been granted. |
| 200345047(PDF, 218K) |
8/13/2003 |
| This letter constitutes notice that a 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. The amount for which the conditional waiver has been granted is the contribution that would otherwise be required to reduce the balance in the funding standard account of the plan to zero as of the end of the plan year for which the waiver has been granted. |
| 200345046(PDF, 205K) |
8/13/2003 |
| This letter constitutes notice that a 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. The amount for which the conditional waiver has been granted is the contribution that would otherwise be required to reduce the balance in the funding standard account of the plan to zero as of the end of the plan year for which the waiver has been granted. |
| 200345045(PDF, 208K) |
8/13/2003 |
| This letter constitutes notice that a 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. The amount for which the conditional waiver has been granted is the contribution that would otherwise be required to reduce the balance in the funding standard account of the plan to zero as of the end of the plan year for which the waiver has been granted. |
| 200345044(PDF, 450K) |
8/14/2003 |
| Request relief under Reg. § 301.91 00-3. |
| 200345043(PDF, 884K) |
8/13/2003 |
| Request a ruling on whether the status of Plan X as a governmental plan under § 414(d) of the Internal Revenue Code will be adversely affected by the inclusion of Community Officers. |
| 200345042(PDF, 813K) |
8/13/2003 |
| Requested ruling concerning the pick up of certain employee contributions to Plan X under 414(h)(2) of the Internal Revenue Code, and the federal income tax treatment of certain transfers of funds from Plan Y to Plan X. |
| 200345041(PDF, 700K) |
8/15/2003 |
| Requested ruling concerning the application of the unrelated business tax provisions to B's proposed student loan and securitization activities. |
| 200345040(PDF, 533K) |
8/12/2003 |
| Requested rulings concerning the taxability of contributions made under a plan described in § 403(b) of the Internal Revenue Code. |
| 200345039(PDF, 90K) |
11/7/2003 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(1)(iii)(A)(3) of the Income Tax Regulations. |
| 200345038(PDF, 61K) |
11/7/2003 |
| Requesting an extension of time under § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make allocations of generation-skipping transfer tax exemption. |
| 200345037(PDF, 45K) |
11/7/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that Company's late election under § 1362(a) to be an S corporation will be treated as timely made. |
| 200345036(PDF, 90K) |
11/7/2003 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(1)(iii)(A)(3) of the Income Tax Regulations. Information was submitted pursuant to § 1.468A-3(h)(2). |
| 200345035(PDF, 61K) |
11/7/2003 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on October 22, 1998. Information was submitted pursuant to § 1.468A-3(h)(2). |
| 200345034(PDF, 49K) |
11/7/2003 |
| Requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200345033(PDF, 49K) |
11/7/2003 |
| Requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200345032(PDF, 49K) |
11/7/2003 |
| Requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200345031(PDF, 49K) |
11/7/2003 |
| Requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200345030(PDF, 66K) |
11/7/2003 |
| Requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200345029(PDF, 66K) |
11/7/2003 |
| Requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200345028(PDF, 49K) |
11/7/2003 |
| Requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200345027(PDF, 49K) |
11/7/2003 |
| Requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200345026(PDF, 60K) |
11/7/2003 |
| Requesting rulings under § 1014 of the Internal Revenue Code. |
| 200345025(PDF, 55K) |
11/7/2003 |
| Request for rulings under § 280G and 4999 of the Internal Revenue Code. Specifically, the letter requests rulings that the proposed merger does not cause a change in ownership or effective control of, or a change in a substantial portion of assets of Company 1 and that the provisions of § 280G and 4999 do not apply to payments made contingent on this transaction. |
| 200345024(PDF, 67K) |
11/7/2003 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(1)(iii)(A)(3) of the Income Tax Regulations. |
| 200345023(PDF, 65K) |
11/7/2003 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(1)(iii)(A)(3) of the Income Tax Regulations. |
| 200345022(PDF, 70K) |
11/7/2003 |
| Ruling request under § 142(d) of the Internal Revenue Code of 1986 that certain types of leases of certain units in a residential rental project financed with the Bonds will not cause the Project to be treated as: (1) used on a transient basis under § 1.103-8(b)(4) of the Income Tax Regulations, or (2) unavailable to members of the general public under § 1.103-8(a)(2) for purposes of § 142(d). |
| 200345021(PDF, 66K) |
11/7/2003 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(1)(iii)(A)(3) of the Income Tax Regulations. |
| 200345020(PDF, 61K) |
11/7/2003 |
| Request to allow the members of D to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments. |
| 200345019(PDF, 48K) |
11/7/2003 |
| Requesting a ruling concerning the qualifying income exception to the publicly traded partnership rules of § 7704 of the Internal Revenue Code. |
| 200345018(PDF, 67K) |
11/7/2003 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(1)(iii)(A)(3) of the Income Tax Regulations. |
| 200345017(PDF, 67K) |
11/7/2003 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i)(1)(iii)(A)(3) of the Income Tax Regulations. |
| 200345016(PDF, 73K) |
11/7/2003 |
| Requesting a letter ruling concerning whether the transfer of an intertie from Generator to Taxpayer is a nonshareholder contribution to capital excludable from Taxpayer’s income under § 118(a) of the Internal Revenue Code. |
| 200345015(PDF, 49K) |
11/7/2003 |
| Requesting that the Service grant W 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. |
| 200345014(PDF, 74K) |
11/7/2003 |
| Ruling request: (1) Any amount paid from the segregated fund for the health insurance coverage of a furloughed employee is excludable from the gross income of the furloughed employee under § 104(a)(3). (2) Any amount deducted from a contributing member's pay on account of the special assessment must be included in the contributing member's gross income. |
| 200345013(PDF, 49K) |
11/7/2003 |
| Request for a ruling to determine your federal employment tax status. You have filed this request in response to an Internal Revenue Service letter dated January 3, 2003, stating that your 1099-MISC income cannot be changed from Schedule C to wage income without a favorable SS-8 determination. |
| 200345012(PDF, 24K) |
11/7/2003 |
| Requesting a ruling under § 162(m) of the Internal Revenue Code. Specifically, a ruling is requested that the deduction limitation of § 162(m) of the Code does not apply to awards granted under the Plan before the first meeting of shareholders of Company in the fifth year after the year in which Company’s shareholders most recently approved the performance goals under the Plan, regardless of when Company actually makes payments pursuant to the awards. |
| 200345011(PDF, 18K) |
11/7/2003 |
| Ruling request under Internal Revenue Code § 877 as provided by § IV of Notice 97-19, as modified by Notice 98-34. |
| 200345010(PDF, 72K) |
11/7/2003 |
| Requesting rulings on certain federal income tax consequences of a proposed transaction. |
| 200345009(PDF, 56K) |
11/7/2003 |
| Requests a ruling on the consequences of a judicial reformation of a Deed of Trust under § 2601 of the Internal Revenue Code |
| 200345008(PDF, 56K) |
11/7/2003 |
| Requesting a ruling on behalf of Portfolios A through Q as their authorized representative. Specifically, you have requested a ruling that each of the Portfolios be granted an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an election under § 855(a) of the Internal Revenue Code for its tax year ended Date 2. |
| 200345007(PDF, 54K) |
11/7/2003 |
| Requesting rulings concerning the creation of new membership interest units in X and the conversion of the existing membership interest units into the newly created membership interest units. |
| 200345006(PDF, 104K) |
11/7/2003 |
| Requesting rulings under § 2036, 2038, 2041 and 2601 of the Internal Revenue Code. |
| 200345005(PDF, 45K) |
11/7/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200345004(PDF, 56K) |
11/7/2003 |
| Request for an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to file Form 8328, Carryforward Election of Unused Private Activity Bond Volume Cap, to make a carryforward election under § 146(f) of the Internal Revenue Code of $a in unused Year 1 private activity bond volume cap. |
| 200345003(PDF, 45K) |
11/7/2003 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200345002(PDF, 56K) |
11/7/2003 |
| 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 a timely allocation of generation skipping transfer exemption with respect to a transfer made by Grantor to an irrevocable trust. |
| 200345001(PDF, 57K) |
11/7/2003 |
| 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 a timely allocation of generation skipping transfer exemption with respect to a transfer made by Grantor to an irrevocable trust. |
