Chief Counsel's Written Determinations Issued from 200400000 to 200404999

Taxpayer-specific rulings or determinations are written memoranda furnished by the IRS National Office in response to requests by taxpayers under published annual guidelines. Technical advice memoranda are written memoranda furnished by the National Office of the IRS upon request of a district director or chief appeals officer pursuant to annual review procedures. Chief Counsel advice are written advice or instructions prepared by the Office of Chief Counsel and issued to field or service center employees of the IRS or Office of Chief Counsel.

It is important to note that pursuant to 26 USC § 6110(j)(3), such items cannot be used or cited as precedent.

200404059(PDF, 331K)	10/29/2003
Requesting rulings under § 414(d) of the Internal Revenue Code.
200404058(PDF, 408K)	10/30/2003
Request for rulings on certain federal income tax consequences of a proposed transaction.
200404057(PDF, 1.6M)	10/29/2003
Request that a nonprofit organization which is exempt from federal income tax under § 501(c)(3) of the Internal Revenue Code and which has also been classified as other than a private foundation under § 509(a)(2).
200404056(PDF, 235K)	10/27/2003
Requested waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200404055(PDF, 541K)	10/29/2003
Request for certain rulings under § 501(c)(9), 512, and 419 of the Internal Revenue Code, submitted on M's behalf by M's authorized representative.
200404054(PDF, 265K)	10/28/2003
Requested waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200404053(PDF, 283K)	10/28/2003
Requested waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200404052(PDF, 370K)	10/27/2003
Requested ruling concerning the federal income tax treatment, under § 414(h)(2) of the Internal Revenue Code, of certain contributions to Plan X.
200404051(PDF, 274K)	10/30/2003
Request a ruling to waive the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200404050(PDF, 472K)	10/20/2003
Request a series of letter rulings under § 401(a)(4), 401(k)(3), 401(m), 402(g), 404, 415, 4972, and 4979 of the Internal Revenue Code.
200404049(PDF, 91K)	1/23/2004
Issue: Whether, in light of the Supreme Court's recent decision in Young v. United States, 535 U.S. 43 (2002), the principle of equitable tolling operates to suspend the 3-year “look-back” period set forth in Bankruptcy Code § 507(a)(8)(A)(i) for the time period during which a taxpayer's offer in compromise is pending with the Service.
200404048(PDF, 77K)	1/23/2004
Issues: (1) Taxpayer is a duly ordained minister of a church who is not opposed to the acceptance of public insurance. Taxpayer subsequently has a change of faith and is ordained as a minister in another church, which results in a change in belief by taxpayer to being opposed to the acceptance of public insurance. Taxpayer seeks exemption from self employment tax under section 1402(e) of the IRC. What language must the taxpayer provide when submitting a Form 4361, Application for Exemption From Self Employment Tax for Use by Ministers, Members of Religious Orders and Christian Science Practitioners, or when submitting an additional statement along with the Form 4361 that sets forth taxpayer’s opposition to the acceptance of any public insurance that arises from a change of faith and a resulting change in belief by the taxpayer to opposing the acceptance of public insurance? (2) Taxpayer is a duly ordained minister of a church who because of religious principles is opposed to the acceptance of public insurance. Taxpayer filed a Form 4361 that the Service did not approve for reasons of late filing. Taxpayer subsequently has a change of faith and is ordained as a minister in another church and taxpayer has no resulting change in belief regarding public insurance. May the taxpayer file another Form 4361? (3) Taxpayer is a duly ordained minister of a church. Taxpayer applies for exemption from self employment taxes by filing a Form 4361. On line 3 of the Form 4361, taxpayer enters the date of January 1, 2000 as the date that he was ordained. Does this mean that for purposes of line 5 of the form, that earnings cannot start until January 1, 2001?
200404047(PDF, 35K)	1/23/2004
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200404046(PDF, 28K)	1/23/2004
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200404045(PDF, 53K)	1/23/2004
Requesting that the Service grant X an extension of time pursuant to § 1362(f) of the Internal Revenue Code.
200404044(PDF, 43K)	1/23/2004
Requesting a ruling on whether water rights are of like-kind with a fee simple interest in farm land under § 1031 of the Internal Revenue Code.
200404043(PDF, 60K)	1/23/2004
Request for a supplemental ruling with respect to a ruling letter PLR-160185-02, LTR 200327051. This letter modifies and supercedes the prior letter dated April 3, 2003.
200404042(PDF, 36K)	1/23/2004
Requests an extension of time under Treasury Regulation § 301.9100-3 to file Form 8848, Consent To Extend the Time to Assess the Branch Profits Tax Under Regulations Sections 1.884-2(a) and (c), for the tax year ended on Date A.
200404041(PDF, 61K)	1/23/2004
Requesting consent, under Treasury Regulation § 1.1295-3(f) to make retroactive qualified electing fund elections to treat the stock indirectly owned by Taxpayers in each passive foreign investment company listed below as stock in a Qualified Electing Fund effective as of the first taxable year Taxpayers owned stock in each Passive Foreign Investment Company.
200404040(PDF, 64K)	1/23/2004
Requesting consent, under Treasury Regulation § 1.1295-3(f), to make retroactive qualified electing fund elections to treat the stock directly and indirectly owned by Taxpayers in each passive foreign investment company listed below as stock in a Qualified Electing Fund effective as of the first taxable year Taxpayers owned such stock.
200404039(PDF, 61K)	1/23/2004
Requesting consent, under Treasury Regulation § 1.1295-3(f) to make retroactive qualified electing fund elections to treat the stock indirectly owned by Taxpayers in each passive foreign investment company listed below as stock in a Qualified Electing Fund effective as of the first taxable year Taxpayers owned stock in each Passive Foreign Investment Company.
200404038(PDF, 60K)	1/23/2004
Requesting consent, under Treasury Regulation § 1.1295-3(f), to make a retroactive qualified electing fund election to treat the stock owned by Taxpayer in the passive foreign investment company listed below as stock in a Qualified Electing Fund effective as of the first taxable year that Taxpayer owned stock in the Passive Foreign Investment Company.
200404037(PDF, 40K)	1/23/2004
Requesting a ruling regarding whether a life tenant who holds stock under a life estate qualifies as an eligible shareholder for S corporation purposes under §1361 of the Internal Revenue Code.
200404036(PDF, 37K)	1/23/2004
Requesting a ruling that Taxpayers be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 469(c)(7)(A) of the Internal Revenue Code and § 1.469-9(g)(3) of the Income Tax Regulations to treat all interests in rental real estate as a single rental real estate activity commencing in Year 1.
200404035(PDF, 39K)	1/23/2004
Requesting permission under § 453(d)(3) of the Internal Revenue Code and § 15A.453-1(d)(4) of the temporary Income Tax Regulations to revoke the election out of the installment method for a certain sale of real property during the Year 1 taxable year.
200404034(PDF, 41K)	1/23/2004
Issue: If a consolidated group of corporations includes both life and non-life members, are the excess inclusion rules of § 860E(a)(1) of the Internal Revenue Code applied at the subgroup level or the consolidated group level.
200404033(PDF, 39K)	1/23/2004
Requesting a time extension 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 and relief under § 1362(b)(5) of the Internal Revenue Code.
200404032(PDF, 33K)	1/23/2004
Requesting a letter ruling under § 301.9100-3 of the Procedure and Administration Regulations to extend the time to make the election provided under § 168(k)(2)(C)(iii) of the Internal Revenue Code, not to deduct the 30-percent additional first year depreciation for qualified property placed in service in the taxable year that included September 11, 2001.
200404031(PDF, 39K)	1/23/2004
Requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations to treat LLC as an association for federal tax purposes and relief under § 1362(b)(5) of the Internal Revenue Code.
200404030(PDF, 50K)	1/23/2004
Requested a ruling and closing agreement that premiums received by Taxpayer on policies of insurance or reinsurance of US risks are exempt from the insurance excise tax imposed by § 4371 of the Code, pursuant to the US-Ireland Income Tax Convention.
200404029(PDF, 50K)	1/23/2004
Requested a ruling and closing agreement that premiums received by Taxpayer on policies of insurance or reinsurance of US risks are exempt from the insurance excise tax imposed by § 4371 of the Code, pursuant to the US-Ireland Income Tax Convention.
200404028(PDF, 61K)	1/23/2004
Requesting consent under Treasury Regulation § 1.1295-3(f), to make retroactive qualified electing fund elections to treat the stock indirectly owned by Taxpayers in each passive foreign investment company listed below as stock in a Qualified Electing Fund effective as of the first taxable year Taxpayers owned stock in each PFIC.1
200404027(PDF, 50K)	1/23/2004
Requesting the consent of the Commissioner of Internal Revenue to make a retroactive qualified electing fund election under § 1295 of the Code and corresponding Treasury Regulation § 1.1295-3(f).
200404026(PDF, 66K)	1/23/2004
Requesting consent under Treasury Regulation § 1.1295-3(f), to make retroactive qualified electing fund elections to treat the stock owned by Taxpayer in each passive foreign investment company listed below as stock in a qualified electing fund effective as of the first taxable year that Taxpayer owned stock in each passive foreign investment company.
200404025(PDF, 40K)	1/23/2004
Requesting a ruling that Company be given an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file a Form 8832, Entity Classification Election, to change its classification pursuant to § 301.77013(c) effective for Date 1.
200404024(PDF, 77K)	1/23/2004
Request on behalf of the Issuer for a ruling that the Issuer will be not treated as a “related party” to either X or Y for purposes of § 1.150-1(b) and § 1.150-1(d)(2)(ii)(A) of the Income Tax Regulations.
200404023(PDF, 35K)	1/23/2004
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200404022(PDF, 115K)	1/23/2004
Submitted on behalf of Grandchild 6 by Grandchild 6's authorized representative, requesting certain rulings under the Internal Revenue Code.
200404021(PDF, 115K)	1/23/2004
Submitted on behalf of Child 2 by Child 2's authorized representative, requesting certain rulings under the Internal Revenue Code.
200404020(PDF, 115K)	1/23/2004
Submitted on behalf of Grandchild 7 by Grandchild 7's authorized representative, requesting certain rulings under the Internal Revenue Code.
200404019(PDF, 68K)	1/23/2004
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.
200404018(PDF, 115K)	1/23/2004
Submitted on behalf of Child 3 by Child 3's authorized representative, requesting certain rulings under the Internal Revenue Code.
200404017(PDF, 115K)	1/23/2004
Submitted on behalf of the estate of Child 1 by Child 1's authorized representative, requesting certain rulings under the Internal Revenue Code.
200404016(PDF, 62K)	1/23/2004
Requesting permission for Corporation to revoke its election under § 41(c)(4) of the Internal Revenue Code.
200404015(PDF, 87K)	1/23/2004
Request for permission to make a late election out of the installment method with respect to the sale described below.
200404014(PDF, 113K)	1/23/2004
Requesting certain rulings, submitted on behalf of Grandchild 5 by Grandchild 5's authorized representative, under the Internal Revenue Code.
200404013(PDF, 98K)	1/23/2004
Requesting gift, estate and income tax rulings under the applicable provisions of the Internal Revenue Code.
200404012(PDF, 115K)	1/23/2004
Requesting certain rulings, submitted on behalf of Grandchild 2 by Grandchild 2's authorized representative, under the Internal Revenue Code.
200404011(PDF, 98K)	1/23/2004
Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to sever a trust pursuant to § 26.2654-1(b)(1) of the Generation-Skipping Transfer Tax Regulations, and to make a “reverse” qualified terminable interest property election under § 2652(a)(3) of the Internal Revenue Code.
200404010(PDF, 107K)	1/23/2004
Requesting certain rulings under § 721 of the Internal Revenue Code regarding the contribution of certain assets to P.
200404009(PDF, 150K)	1/23/2004
Requesting gift, estate and income tax rulings under the applicable provisions of the Internal Revenue Code.
200404008(PDF, 74K)	1/23/2004
Requesting that Parent be given an extension of time in which to elect to treat its subsidiaries as qualified subchapter S subsidiaries under § 1361(b)(3) of the Internal Revenue Code.
200404007(PDF, 113K)	1/23/2004
Requesting certain rulings, submitted on behalf of Grandchild 3 by Grandchild 3's authorized representative, under the Internal Revenue Code.
200404006(PDF, 114K)	1/23/2004
Requesting certain rulings, submitted on behalf of Grandchild 1 by Grandchild 1's authorized representative, under the Internal Revenue Code.
200404005(PDF, 113K)	1/23/2004
Requesting certain rulings under the Internal Revenue Code.
200404004(PDF, 124K)	1/23/2004
Requesting rulings on behalf of the personal representative of the above captioned estate regarding the application of federal estate, gift, and generation-skipping transfer tax to the proposed reformation of a trust.
200404003(PDF, 106K)	1/23/2004
Request for rulings dated June 2, 2003, submitted on behalf of Coop by its authorized representative concerning the proper tax treatment of a transaction fully described below.
200404002(PDF, 98K)	1/23/2004
Requesting a letter ruling concerning whether a transfer of an Intertie from Generator to Taxpayer is a non-shareholder contribution to capital excludable from income under § 118(a) of the Internal Revenue Code.
200404001(PDF, 17K)	1/23/2004
Requested ruling with respect to the operations of Taxpayer (8623005). That Technical Advice Memorandum concerned the excise tax imposed on the amount paid for the air transportation of persons by § 4261 of the Internal Revenue Code.
200403099(PDF, 251K)	10/20/2003
Request a waiver of 408(d)(3) of the 60-day rollover the requirement contained in § Internal Revenue Code.
200403098(PDF, 310K)	10/22/2003
Request a waiver of 408(d)(3) of the 60-day rollover the requirement contained in § Internal Revenue Code.
200403097(PDF, 175K)	10/24/2003
Request ruling with respect to the benefit pension plan, whether the plan amendment described is reasonable and provides for de minimis increases in plan liabilities of the Plan within the meaning of § 401(a)(33)(A) of the Code and § 204(i)(l) of Employee Retirement Income Security Act.
200403096(PDF, 17K)	1/16/2004
PULLED
200403095(PDF, 116K)	1/16/2004
Request for a ruling that Corporation may calculate a single yield on the Organization 1 Bonds and that it may calculate a single yield on the Organization 2 Bonds on behalf of Subsidiary 1 and Subsidiary 2, respectively, for purposes of § 148 of the IRC.
200403094(PDF, 99K)	1/16/2004
Requesting rulings regarding the federal estate and gift tax consequences of the proposed creation of a trust.
200403093(PDF, 89K)	1/16/2004
Requesting a ruling that the Service disregard the qualified terminable interest property election made on the Decedent’s federal estate tax return.
200403092(PDF, 86K)	1/16/2004
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.
200403091(PDF, 109K)	1/16/2004
Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations.
200403090(PDF, 109K)	1/16/2004
Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations.
200403089(PDF, 110K)	1/16/2004
Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations.
200403088(PDF, 108K)	1/16/2004
Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations.
200403087(PDF, 103K)	1/16/2004
Requesting a letter ruling concerning whether the transfer of an intertie from Generator to Taxpayer is a non-shareholder contribution to capital excludable from income under § 118(a) of the Internal Revenue Code.
200403086(PDF, 104K)	1/16/2004
Requesting a letter ruling concerning whether the transfer of an intertie from Generator to Taxpayer is a non-shareholder contribution to capital excludable from income under § 118(a) of the Internal Revenue Code.
200403085(PDF, 102K)	1/16/2004
Requesting a letter ruling concerning whether the transfer of an intertie from Generator to Taxpayer is a non-shareholder contribution to capital excludable from income under § 118(a) of the Internal Revenue Code.
200403084(PDF, 99K)	1/16/2004
Requesting a letter ruling concerning whether the transfer of an intertie from Generator to Taxpayer is a non-shareholder contribution to capital excludable from income under § 118(a) of the Internal Revenue Code.
200403083(PDF, 69K)	1/16/2004
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.
200403082(PDF, 21K)	1/16/2004
Requesting permission to adopt, for federal income tax purposes, a taxable year ending October 31, effective for the taxpayer’s taxable year beginning February 12, 2002, and ending October 31, 2002.
200403081(PDF, 80K)	1/16/2004
Requesting a ruling under § 1362(f) of the Internal Revenue Code.
200403080(PDF, 80K)	1/16/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of Generation-Skipping Transfer Tax exemption.
200403079(PDF, 80K)	1/16/2004
Requesting time extensions 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 and to elect to treat Y as a qualified subchapter S subsidiary.
200403078(PDF, 73K)	1/16/2004
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) and 1375 of the Internal Revenue Code.
200403077(PDF, 81K)	1/16/2004
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 generation-skipping transfer exemption to lifetime transfers made to three irrevocable trusts.
200403076(PDF, 103K)	1/16/2004
Requesting a letter ruling concerning whether the transfer of interconnection facilities to Taxpayer is a non-shareholder contribution to capital excludable from Taxpayer’s income under § 118(a) of the Internal Revenue Code.
200403075(PDF, 78K)	1/16/2004
Requested a ruling that premiums received by the Taxpayer on policies of insurance or reinsurance of U.S. risks are exempt from the insurance excise tax imposed by § 4371 of the IRC of 1986, pursuant to the United States-Ireland income tax convention.
200403074(PDF, 72K)	1/16/2004
Request an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election.
200403073(PDF, 99K)	1/16/2004
Requesting letter rulings under §§ 61 and 118 of the Internal Revenue Code.
200403072(PDF, 101K)	1/16/2004
Requested rulings on behalf of Donor’s estate concerning an extension of time to allocate Donor’s available generation-skipping transfer exemption to transfers to an irrevocable trust pursuant to § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations, the GST tax consequences of severing the trust, and the merging of one of the resulting trusts.
200403071(PDF, 96K)	1/16/2004
Request for a schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund because Taxpayer recently acquired the Plant from Transferor.
200403070(PDF, 99K)	1/16/2004
Request for a schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund because Taxpayer recently acquired the Plant from Transferor.
200403069(PDF, 100K)	1/16/2004
Request for a schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund because Taxpayer recently acquired the Plant from Transferor.
200403068(PDF, 97K)	1/16/2004
Request for a schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund because Taxpayer recently acquired the Plant from Transferor.
200403067(PDF, 96K)	1/16/2004
Request for a schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund because Taxpayer recently acquired the Plant from Transferor.
200403066(PDF, 96K)	1/16/2004
Request for a schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund because Taxpayer recently acquired the Plant from Transferor.
200403065(PDF, 107K)	1/16/2004
Request for a revised schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund in accordance with § 1.468A-3(i) of the Income Tax regulations.
200403064(PDF, 107K)	1/16/2004
Request for a revised schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund in accordance with § 1.468A-3(i) of the Income Tax regulations.
200403063(PDF, 107K)	1/16/2004
Request for a revised schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund in accordance with § 1.468A-3(i) of the Income Tax regulations.
200403062(PDF, 107K)	1/16/2004
Request for a revised schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund in accordance with § 1.468A-3(i) of the Income Tax regulations.
200403061(PDF, 66K)	1/16/2004
In reference to 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 September 30 Year.
200403060(PDF, 210K)	1/16/2004
Request for rulings on certain federal income tax consequences of a proposed transaction.
200403059(PDF, 101K)	1/16/2004
Requesting letter rulings under §61 and §118 of the Internal Revenue Code.
200403058(PDF, 103K)	1/16/2004
Requesting letter rulings under §61 and §118 of the Internal Revenue Code.
200403057(PDF, 103K)	1/16/2004
Requesting letter rulings under §61 and §118 of the Internal Revenue Code.
200403056(PDF, 84K)	1/16/2004
Request for a ruling concerning whether payments made under a retirement plan maintained by the Firm for retired partners satisfies the requirements of IRC § 1402(a)(10), and are, therefore, excludible from gross income when determining net earnings from self-employment.
200403055(PDF, 84K)	1/16/2004
Requested ruling that the Authority may continue to rely on the following conclusions reached in the private letter ruling issued to the Authority on Date 1 despite the factual changes that have occurred since Date 1: (1) The Authority’s allocation of 50% of the Trench Costs to the Street Improvements will not cause the Bonds or the New Bonds to be private activity bonds under § 141. (2) The facts and circumstances weigh against application of the anti-abuse rule of § 1.141-14 of the Income Tax Regulations to reallocate the proceeds of the Bonds or the New Bonds to other purposes.
200403054(PDF, 70K)	1/16/2004
Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an entity classification election under § 301.7701-3.
200403053(PDF, 69K)	1/16/2004
Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an entity classification election under § 301.7701-3.
200403052(PDF, 69K)	1/16/2004
Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an entity classification election under § 301.7701-
200403051(PDF, 92K)	1/16/2004
Requesting rulings concerning the termination of Trust.
200403050(PDF, 86K)	1/16/2004
Requested on your behalf rulings under § 117(d) of the IRC of 1986 regarding the proper federal income tax treatment of certain tuition reduction benefits provided by you, X, under the College's tuition reduction program.
200403049(PDF, 38K)	1/16/2004
Requesting a ruling on whether you are eligible to exclude gain from the sale of Residence under § 121(c) of the Internal Revenue Code.
200403048(PDF, 99K)	1/16/2004
Requesting rulings on certain federal income tax consequences of a proposed transaction.
200403047(PDF, 34K)	1/16/2004
Requesting a ruling under § 877(c) of the IRC of 1986 that A’s loss of 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.
200403046(PDF, 48K)	1/16/2004
Requesting a ruling that a portion of legal costs (attorney fees and other litigation costs) paid to B’s attorney pursuant to a settlement agreement will not be included in B’s gross income.
200403045(PDF, 36K)	1/16/2004
Requesting a ruling that A’s surrender of her green card (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.
200403044(PDF, 131K)	1/16/2004
Requesting a ruling on the proper federal income tax treatment of a proposed grant of a conservation easement by Taxpayer to Donee, which is a supporting organization of Corp A.
200403043(PDF, 43K)	1/16/2004
Requesting a ruling that X, Y, and Z may determine the credit for increasing research activities under the standard method of § 41(a) of the IRC for the taxable year ending on a and all subsequent taxable years.
200403042(PDF, 34K)	1/16/2004
Requesting an extension under § 301.9100-3 of the Procedure and Administration Regulations for X to be treated as an association taxable as a corporation for federal tax purposes.
200403041(PDF, 47K)	1/16/2004
Requesting that we supplement our letter ruling PLR-103061-99. The legend abbreviations, facts, proposed transaction, representations, and caveats appearing in the Prior Letter Ruling are hereby incorporated by reference.
200403040(PDF, 53K)	1/16/2004
Requesting an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election.
200403039(PDF, 46K)	1/16/2004
Requesting, on behalf of Taxpayer, an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election.
200403038(PDF, 36K)	1/16/2004
Requesting a ruling, under § 301.9100-3 of the Procedure and Administration Regulations, that X be granted an extension of time to elect to be treated as an association taxable as a corporation under § 301.7701-3(c).
200403037(PDF, 85K)	1/16/2004
Requesting a letter ruling concerning whether the transfer of an intertie by Generator to Taxpayer will be a non-shareholder contribution to capital excludable from income under § 118(a) of the Internal Revenue Code.
200403036(PDF, 36K)	1/16/2004
Requesting and extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations to elect to treat X1 as a qualified subchapter S subsidiary for federal tax purposes.
200403035(PDF, 33K)	1/16/2004
Requests an extension of time under Treasury Regulation § 301.9100-3 to submit a ruling request under § 877 as provided by § IV of Notice 97-19, as modified by Notice 98-34.
200403034(PDF, 35K)	1/16/2004
Requesting an extension under § 301.9100-3 of the Procedure and Administration Regulations for LLC to elect to be treated as an association taxable as a corporation for federal tax purposes.
200403033(PDF, 36K)	1/16/2004
Requesting a private letter ruling that certain loan assistance payments made to former College students who are foreign nationals employed outside of the United States are foreign source income.
200403032(PDF, 37K)	1/16/2004
Requesting a ruling that A’s loss of U.S. citizenship (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.
200403031(PDF, 63K)	1/16/2004
Requesting a ruling that each of Trusts 1 through 8, as reformed, is a qualified subchapter S trust under § 1361(d)(3) of the IRC and is exempt for generation skipping tax purposes.
200403030(PDF, 48K)	1/16/2004
Requested a ruling permitting Taxpayer to offset its surplus in accumulated earnings and profits by its real estate investment trust predecessor’s cumulative deficit in earnings and profits for purposes of satisfying the requirement in § 857(a)(2)(B) of the IRC.
200403029(PDF, 86K)	1/16/2004
Requesting a letter ruling concerning whether the transfer of Interconnection Facilities to Taxpayer is a non-shareholder contribution to capital excludable from Taxpayer’s income under § 118(a) of the Internal Revenue Code.
200403028(PDF, 37K)	1/16/2004
Requesting a ruling, under § 301.9100-3 of the Procedure and Administration Regulations, that X be granted an extension of time to elect to be treated as an association taxable as a corporation under § 301.7701-3(c).
200403027(PDF, 39K)	1/16/2004
Requested a ruling that for purposes of § 856(a)(6) and (h)(1)(A) of the Internal Revenue Code, stock held by certain tax-exempt organizations is not treated as stock held by an individual under § 542(a)(2).
200403026(PDF, 50K)	1/16/2004
Requesting a ruling that Hospital may be treated as an integral part of City for federal income tax purposes and that charitable contributions made to Hospital for public purposes are deductible under § 170(c)(1).
200403025(PDF, 91K)	1/16/2004
Internal Revenue Code as an insurance company other than a life insurance company.
200403024(PDF, 63K)	1/16/2004
Requesting rulings that the contracts issued by Taxpayer’s wholly owned subsidiary qualify as insurance contracts for federal income tax purposes and that Insurance Subsidiary is taxable under § 831 of the IRC as an insurance company other than a life insurance company.
200403023(PDF, 32K)	1/16/2004
Requested a ruling regarding whether funds received from City will be treated as income described in § 856(c)(2) of the Internal Revenue Code.
200403022(PDF, 97K)	1/16/2004
Revised schedule of ruling amounts in accordance with § 1.468A-3(i)(1)(i) of the Income Tax Regulations.
200403021(PDF, 95K)	1/16/2004
Request for a revised schedule of ruling amounts in accordance with § 1.468A-3(i)(1)(i) of the Income Tax Regulations.
200403020(PDF, 29K)	1/16/2004
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200403019(PDF, 75K)	1/16/2004
Requested rulings on certain federal income tax consequences of a proposed transaction.
200403018(PDF, 44K)	1/16/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election.
200403017(PDF, 44K)	1/16/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election.
200403016(PDF, 42K)	1/16/2004
Request ruling to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403015(PDF, 42K)	1/16/2004
Request ruling to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403014(PDF, 42K)	1/16/2004
Request ruling to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403013(PDF, 41K)	1/16/2004
Request ruling to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403012(PDF, 41K)	1/16/2004
Request ruling to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403011(PDF, 42K)	1/16/2004
Request ruling to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403010(PDF, 42K)	1/16/2004
Request ruling to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403009(PDF, 42K)	1/16/2004
Request ruling to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403008(PDF, 42K)	1/16/2004
Request ruling to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403007(PDF, 42K)	1/16/2004
Request to allow the taxpayer, A, to use an alternative method of basis recovery under § 15a.453-1(c)(7) of the Temporary Income Tax Regulations to report contingent payments, because the normal basis recovery rule method will substantially and inappropriately defer recovery of basis.
200403006(PDF, 95K)	1/16/2004
Request for a revised schedule of ruling amounts in accordance with § 1.468A-3(i)(1)(i) of the Income Tax Regulations.
200403005(PDF, 45K)	1/16/2004
Requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make an election under § 856(l) of the Internal Revenue Code to treat Company B as a taxable REIT subsidiary of Company A.
200403004(PDF, 41K)	1/16/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be disregarded as an entity separate from its owner for federal tax purposes under § 301.7701-3(c).
200403003(PDF, 41K)	1/16/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as a partnership for federal tax purposes under § 301.7701-3(c).
200403002(PDF, 40K)	1/16/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as a partnership for federal tax purposes under § 301.7701-3(c).
200403001(PDF, 79K)	1/16/2004
Issue: (1) Whether Model A dump truck is excepted from the definition of a highway vehicle under § 48.4061(a)-1(d)(2)(ii) of the Manufacturers and Retailers Excise Tax Regulations and therefore not subject to the tax imposed by § 4051(a)(1)? (2) If the Model A is considered a taxable highway vehicle, is Taxpayer’s liability for tax affected by its acceptance of a statement from the purchaser that the truck is purchased for off-road use?
200402031(PDF, 363K)	10/15/2003
Requesting a ruling under § 414(d) of the Internal Revenue Code.
200402030(PDF, 154K)	10/15/2003
Request of a conditional waiver of the minimum funding standard for the plan year ended December 31, 2002.
200402029(PDF, 458K)	10/16/2003
Request of a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200402028(PDF, 235K)	10/14/2003
Request of a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200402027(PDF, 426K)	10/14/2003
Ruling request concerning the pick up of certain employee contributions to Plan Y under § 414(h)(2) of the Internal Revenue Code.
200402026(PDF, 132K)	10/14/2003
Request of a waiver of the minimum funding standard has been granted for the above-named pension plan for the plan year beginning December 1, 2002.
200402025(PDF, 201K)	10/14/2003
Request of a waiver of the minimum funding standard has been granted for the above-named pension plan for the plan year beginning January 1, 2002.
200402024(PDF, 207K)	10/14/2003
Request of a waiver of the minimum funding standard has been granted for the above-named pension plan for the plan year beginning January 1, 2002.
200402023(PDF, 174K)	10/14/2003
Request of a waiver of the minimum funding standard has been granted for the above-named pension plan for the plan year beginning January 1, 2002.
200402022(PDF, 169K)	10/14/2003
Request of (1) a waiver of the minimum funding standard for the above-named pension plan for the plan year beginning Jan 1, 2002, and (2) waiver of the I00 percent tax under § 4971(b) of IRC for the tax year associated with the plan year beginning January 1, 2001.
200402021(PDF, 75K)	1/9/2004
Requesting a ruling under § 1362(f) of the Internal Revenue Code.
200402020(PDF, 91K)	1/9/2004
Requesting rulings under §§ 1001, 2501, and 2601 of the Internal Revenue Code.
200402019(PDF, 106K)	1/9/2004
Requesting rulings on the tax consequences of a proposed transaction.
200402018(PDF, 76K)	1/9/2004
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 generation-skipping transfer exemptions to transfers to trusts.
200402017(PDF, 76K)	1/9/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code, to make an allocation of Generation-Skipping Transfer Tax exemption.
200402016(PDF, 76K)	1/9/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code, to make an allocation of Generation-Skipping Transfer Tax exemption.
200402015(PDF, 81K)	1/9/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of Generation-Skipping Transfer Tax exemption.
200402014(PDF, 81K)	1/9/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make an allocation of Generation-Skipping Transfer Tax exemption.
200402013(PDF, 71K)	1/9/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election.
200402012(PDF, 96K)	1/9/2004
Requesting 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 charitable remainder trust.
200402011(PDF, 82K)	1/9/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election.
200402010(PDF, 83K)	1/9/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election.
200402009(PDF, 107K)	1/9/2004
Requesting rulings on the tax consequences of a proposed transaction.
200402008(PDF, 78K)	1/9/2004
Issues: (1) When one or more employees of a promoter organize a single entity or engage in a single sale, can a penalty under § 6700 apply separately to each employee and the employer? (2) What activities constitute organizational activities as used in § 6700(a)(1)(A)? (3) What activities constitute participating in the sale of an entity, plan or arrangement under § 6700(a)(1)(B)?
200402007(PDF, 51K)	1/9/2004
Whether the dual notice requirement of § 3201(d) of the Internal Revenue Service Restructuring and Reform Act of 1998 can be waived by joint filers during an examination.
200402006(PDF, 50K)	1/9/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election.
200402005(PDF, 56K)	1/9/2004
Whether the taxpayers may reasonably rely on a prior audit for § 530 relief under the Revenue Act of 1978, when taxpayers were involved in a fraudulent scheme to evade paying employment taxes for Years 1 through 3.
200402004(PDF, 94K)	1/9/2004
Whether, as a result of an obligation to make a restitution payment, the Taxpayer realized income that may be considered discharge of indebtedness income.
200402003(PDF, 44K)	1/9/2004
Requesting rulings on the federal income tax consequences of a proposed transaction.
200402002(PDF, 38K)	1/9/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as a partnership for federal tax purposes under § 301.7701-3(c).
200402001(PDF, 65K)	1/9/2004
Requesting rulings that the contracts issued by Taxpayer’s wholly owned subsidiary qualify as insurance contracts for federal income tax purposes and that the subsidiary is taxable under § 831 of the IRC as an insurance company other than a life insurance company.
200401025(PDF, 218K)	11/5/2003
Request for a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200401024(PDF, 228K)	11/4/2003
Request for a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200401023(PDF, 227K)	10/9/2003
Requested a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200401022(PDF, 460K)	10/8/2003
Requested ruling under § 414(e) of the Internal Revenue Code.
200401021(PDF, 48K)	10/7/2003
This is in reference to Announcement 97-45, 1997-17 IRB 20 in which the IRS indicated that it was reconsidering PLR 97L2033 issued to you on December 24,1996. In Announcement 97-45, the Service indicated that it was reexamining the plan qualification and other tax issues raised by a contribution of stock options to a qualified plan and the subsequent exercise of those options to be used in the purchase of the common stock of the employer maintaining the plan.
200401020(PDF, 243K)	10/8/2003
Request for a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code.
200401019(PDF, 91K)	10/7/2003
Request for a waiver of the minimum funding standard for the plan year ended December 31, 2000.
200401018(PDF, 164K)	10/10/2003
Request for a waiver of the 10 percent excise tax due under § 4971(f)(l) of the Internal Revenue Code have been granted with respect to the liquidity shortfall for the Plan for the first, second, third, and fourth quarters of the plan year ending October 31, 2002.
200401017(PDF, 71K)	10/10/2003
Request for a waiver of the minimum funding standard for the plan year beginning April 1, 2000.
200401016(PDF, 79K)	10/10/2003
Request for a waiver of the minimum funding standard for the plan year beginning October 1, 2000.
200401015(PDF, 70K)	10/10/2003
Request for a waiver of the minimum funding standard for the plan year ended December 31, 2001.
200401014(PDF, 152K)	10/2/2003
Request for waiver of the minimum funding standard for pension plan for the plan year beginning January 1, 2002, in accordance with § 41 of the Internal Revenue Code and § 303 of the Employee Retirement Income Security Act of 1974.
200401013(PDF, 80K)	1/2/2004
Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Taxpayer to file an election under § 1.1502-21(b)(3)(i) of the Income Tax Regulations, to relinquish the entire carry-back period for the consolidated net operating loss of the consolidated group of which the Taxpayer is the common parent for the tax year ended Date 1.
200401012(PDF, 84K)	1/2/2004
The Funds request that their elections under § 855(a) of the Internal Revenue Code to treat dividends distributed after the close of a taxable year as having been paid during that taxable year be considered timely filed pursuant to § 301.9100-3 of the Procedure and Administration Regulations. Fund P also requests that its election under § 851(b)(1) to be treated as a regulated investment company beginning with its initial taxable year be considered timely filed pursuant to § 301.9100-3.
200401011(PDF, 74K)	1/2/2004
Requesting a ruling under § 1361(e) of the Internal Revenue Code.
200401010(PDF, 84K)	1/2/2004
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 generation-skipping transfer exemption to lifetime transfers made to two irrevocable trusts.
200401009(PDF, 107K)	1/2/2004
Requesting rulings on the tax consequences of a proposed transaction.
200401008(PDF, 44K)	1/2/2004
Requesting an extension of time, under § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is requested in order to allow Parent and Subsidiary to elect to file a consolidated federal income tax return, with Parent as the common parent, under § 1.1502-75(a)(1) of the Income Tax Regulations for Tax Year.
200401007(PDF, 46K)	1/2/2004
Requesting a ruling, under § 301.9100-3 of the Procedure and Administration Regulations, that X be granted an extension of time to elect to be treated as an association taxable as a corporation under § 301.7701-3(c) and § 1362(b)(5) of the Internal Revenue Code that X be granted relief from filing a late S corporation election.
200401006(PDF, 38K)	1/2/2004
Requesting that the Service grant V an extension of time to elect to be treated as a disregarded entity under § 301.7701-3(c) of the Procedure and Administration Regulations.
200401005(PDF, 39K)	1/2/2004
Requesting that the Service grant V an extension of time to elect to be treated as a disregarded entity under § 301.7701-3(c) of the Procedure and Administration Regulations.
200401004(PDF, 37K)	1/2/2004
Requesting that the Service grant V an extension of time to elect to be treated as a disregarded entity under § 301.7701-3(c) of the Procedure and Administration Regulations.
200401003(PDF, 38K)	1/2/2004
Requesting that the Service grant V an extension of time to elect to be treated as a disregarded entity under § 301.7701-3(c) of the Procedure and Administration Regulations.
200401002(PDF, 38K)	1/2/2004
Requesting that the Service grant V an extension of time to elect to be treated as a disregarded entity under § 301.7701-3(c) of the Procedure and Administration Regulations.
200401001(PDF, 31K)	1/2/2004
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 September 30, effective September 30, 2002.
INFO 2004-0235(PDF, 13K)	9/28/2004
Request to Revoke Section 179 Election.
INFO 2004-0234(PDF, 17K)	12/3/2004
Inquiry regarding the exemption of the salary, of a former ambassador to the United States, earned while stationed in the United States and performing official duties for their government, from the U.S. federal income taxation under section 893 of the Internal Revenue Code of 1986 (Code).
INFO 2004-0233(PDF, 15K)	12/13/2004
Recognition of Taxpayer’s election to be an S corporation.
INFO 2004-0232(PDF, 16K)	12/16/2004
Request for information regarding whether § 170 of the Internal Revenue Code allows a deduction for contributions to a certain fund.
INFO 2004-0231(PDF, 20K)	11/30/2004
Request for guidance from the Internal Revenue Service regarding Revenue Ruling 70- 604.
INFO 2004-0230(PDF, 18K)	11/16/2004
Request for general information regarding a person’s qualifications to be a qualified intermediary for like-kind exchanges under § 1031 of the Internal Revenue Code.
INFO 2004-0229(PDF, 15K)	12/13/2004
Requesting a late S election.
INFO 2004-0228(PDF, 14K)	11/19/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0227(PDF, 15K)	11/18/2004
Requesting a late S corporation election.
INFO 2004-0226(PDF, 15K)	12/13/2004
Requesting a late S election.
INFO 2004-0225(PDF, 9K)	12/13/2004
Request for retroactive revocation of Taxpayer’s S election.
INFO 2004-0224(PDF, 14K)	11/12/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0223(PDF, 8K)	11/17/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0222(PDF, 11K)	10/20/2004
Railroad Retirement Act Tax Status.
INFO 2004-0221(PDF, 19K)	11/24/2004
Treatment of Lump-Sum Pension Distributions under U.S. - Canada Income Tax Treaty.
INFO 2004-0220(PDF, 13K)	11/19/2004
Request to recognize Taxpayer’s revocation of its election to be an S corporation.
INFO 2004-0219(PDF, 14K)	11/18/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0218(PDF, 15K)	11/18/2004
Taxpayer requesting a late S corporation election.
INFO 2004-0217(PDF, 11K)	11/12/2004
Taxpayer requesting a late S corporation election.
INFO 2004-0216(PDF, 11K)	11/12/2004
Taxpayer requesting a late S corporation election.
INFO 2004-0215(PDF, 15K)	11/17/2004
Taxpayer requesting a late S corporation election.
INFO 2004-0214(PDF, 14K)	11/9/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0213(PDF, 14K)	11/9/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0212(PDF, 14K)	11/18/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0211(PDF, 14K)	11/9/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0210(PDF, 9K)	10/14/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0209(PDF, 11K)	10/19/2004
Railroad Retirement Act Tax Status.
INFO 2004-0208(PDF, 11K)	9/24/2004
Inquiry regarding the application of sections 457 and 501(c)(1) to federal credit unions.
INFO 2004-0207(PDF, 18K)	9/23/2004
Request for a private letter ruling about rolling over a distribution received from section 457(f) plan account into an individual retirement account (IRA).
INFO 2004-0206(PDF, 18K)	9/22/2004
Inquiry concerning income reported by employer earned performing services part-time through a work study program at a local community college on a Form W-2 (Wage and Tax Statement).
INFO 2004-0205(PDF, 15K)	10/14/2004
Taxpayer requesting a late S corporation election.
INFO 2004-0204(PDF, 9K)	9/29/2004
Request to recognize Taxpayer’s election to be an entity classified as an association taxable as a corporation and Taxpayer’s election to be treated as an S corporation.
INFO 2004-0203(PDF, 8K)	11/22/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0202(PDF, 15K)	9/30/2004
Request to Make a Late Section 179 Election.
INFO 2004-0201(PDF, 22K)	10/21/2004
Request for information regarding certain qualified parking plans.
INFO 2004-0200(PDF, 8K)	9/3/2004
Requesting a late S election.
INFO 2004-0199(PDF, 14K)	11/18/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0198(PDF, 11K)	10/4/2004
Requesting a reinstatement of an S election.
INFO 2004-0197(PDF, 14K)	9/3/2004
Requesting a late S election.
INFO 2004-0196(PDF, 8K)	11/9/2004
Requesting a late S election.
INFO 2004-0195(PDF, 21K)	10/25/2004
Request for a letter ruling concerning the common paymaster provisions of the Internal Revenue Code. As a preliminary matter, apart from the procedure for issuing a formal opinion as described in Revenue Procedure 2004-1, 2004-1 I.R.B. 1, the Internal Revenue Service is not able to provide binding legal advice to particular taxpayers.
INFO 2004-0194(PDF, 8K)	11/9/2004
Taxpayer requesting information regarding the status of its subchapter S election.
INFO 2004-0193(PDF, 17K)	9/30/2004
Request for a ruling concerning entitlement to an expense deduction under section 179 of the Internal Revenue Code on the purchase of a sports utility vehicle with a loaded gross vehicle weight in excess of 6000 pounds.
INFO 2004-0192(PDF, 11K)	9/13/2004
Questions regarding the application of sections 457 and 501(c)(1) to federal credit unions.
INFO 2004-0191(PDF, 14K)	9/17/2004
Request to Revoke Section 179 Election.
INFO 2004-0190(PDF, 9K)	9/23/2004
Taxpayer requesting automatic relief under Revenue Procedure 2002-59 to make a late entity election.
INFO 2004-0189(PDF, 8K)	9/15/2004
Request that the new EIN applied on-line for the Taxpayer be validated.
INFO 2004-0188(PDF, 14K)	9/28/2004
Request to Revoke Section 179 Election.
INFO 2004-0187(PDF, 18K)	9/13/2004
Request for a ruling regarding the cost of using a surrogate mother to bear your child being allowed as an exception to the tax on early distributions from an individual retirement plan under § 401(k) of the Internal Revenue Code. Also for a ruling that the expenses would be deductible under § 213 as medical expenses.
INFO 2004-0186(PDF, 14K)	9/28/2004
Request to Revoke Section 179 Election.
INFO 2004-0185(PDF, 15K)	10/13/2004
Inquiry about the deductibility of expenses incurred by a pilot to be trained as a Federal flight deck officer.
INFO 2004-0184(PDF, 10K)	10/14/2004
Taxpayer requesting relief under Revenue Procedure 2003-43 for a late S corporation election.
INFO 2004-0183(PDF, 13K)	8/30/2004
Request seeking a private letter ruling granting a retroactive late S corporation election.
INFO 2004-0182(PDF, 9K)	10/12/2004
Taxpayer requesting relief under Revenue Procedure 2003-43 for a late S corporation election.
INFO 2004-0181(PDF, 13K)	8/30/2004
Request seeking a retroactive late S corporation election pursuant to Rev. Proc. 97-48.
INFO 2004-0180(PDF, 13K)	9/28/2004
Request to Revoke Section 179 Election.
INFO 2004-0179(PDF, 13K)	11/15/2004
Inquiry regarding the Service’s 2004-2005 Guidance Priority Plan (Plan) to reexamine and clarify the rules determining whether certain agent-drivers and commission drivers are statutory employees (section 3121(d)(3)(A) of the Internal Revenue Code (the Code)). Request to reconsider the position of the IRS regarding the General Counsel Memorandum (GCM) 39853 (June 20, 1991), which concludes that route ownership is not an investment in facilities that exempts a worker from statutory employee status if the investment is substantial. Request to put reconsideration of the GCM on the IRS’s 2004-2005 Plan.
INFO 2004-0178(PDF, 13K)	11/9/2004
Inquiry confirming the IRS awareness of business proposals reducing taxes significantly and help many residents of Washington, Oregon, and other states. Tool rental revenue ruling project announced in the release of the Department of Treasury 2004-2005 Priority Guidance Plan.
INFO 2004-0177(PDF, 18K)	10/15/2004
Inquiry with regards to whether the City can transfer amounts from its eligible governmental section 457(b) deferred compensation plan to a governmental defined benefit plan for the purchase of permissive service credits, without tax consequences.
INFO 2004-0176(PDF, 22K)	10/13/2004
Inquiry regarding an informal opinion received from an IRS tax specialist who indicated that amounts withheld by the European Commission, an institution of the European Union (EU) , from a pension income did not qualify for the foreign tax credit under section 901 of the Internal Revenue Code because the amounts did not constitute taxes imposed by a foreign country. Request to review a Congressional Research Service (CRS) memo that examined the tax specialist’s opinion that included a reference of the private letter ruling 8707031 in support.
INFO 2004-0175(PDF, 18K)	9/28/2004
Tax treatment of federal appropriations.
INFO 2004-0174(PDF, 20K)	9/24/2004
Inquiry regarding IRS audits of state governments in which the Service may be asserting that state agencies are responsible for withholding, depositing, and reporting employment taxes for informal (in-home) child care providers.
INFO 2004-0173(PDF, 18K)	9/24/2004
Tax treatment of federal appropriations.
INFO 2004-0172(PDF, 18K)	8/10/2004
Inquiry regarding the exclusion of a housing allowance from gross income.
INFO 2004-0171(PDF, 8K)	9/7/2004
Request for guidance concerning accountable plans as they relate to situations where individuals provide their own equipment for use when performing services as employees.
INFO 2004-0170(PDF, 12K)	10/18/2004
Inquiry with regard to whether a church could jeopardize its exemption when it invites someone to speak at its services about a political campaign.
INFO 2004-0169(PDF, 25K)	12/9/2004
Request for information on lobbying and influencing public policy by private foundations.
INFO 2004-0168(PDF, 11K)	10/5/2004
The tax-exempt status of lease-purchase arrangements of energy efficient equipment to municipalities and other political subdivisions.
INFO 2004-0167(PDF, 20K)	9/7/2004
Inquiry regarding Form 3115, Application for Change in Accounting Method.
INFO 2004-0166(PDF, 20K)	6/24/2004
The proper tax treatment of travel expense reimbursements paid by the taxpayer to an employee who works out of their residence in one state but who regularly travels to the taxpayer’s office in another state, where they stay in a corporate apartment provided by the taxpayer.
INFO 2004-0165(PDF, 12K)	12/16/2003
Railroad Retirement Act Tax Status.
INFO 2004-0164(PDF, 11K)	3/16/2004
Railroad Retirement Act Tax Status.
INFO 2004-0163(PDF, 11K)	12/17/2003
Railroad Retirement Act Tax Status.
INFO 2004-0162(PDF, 9K)	7/19/2004
Late S corporation relief under section 1362(b)(5) of the Internal Revenue Code.
INFO 2004-0161(PDF, 14K)	7/17/2004
Taxpayer’s election to be an S corporation as well as a Qualified Subchapter S Subsidiary (QSub) election.
INFO 2004-0160(PDF, 13K)	7/22/2004
Request for an advisory opinion considering several alimony issues.
INFO 2004-0159(PDF, 15K)	7/26/2004
Taxpayer requesting a late S corporation election.
INFO 2004-0158(PDF, 9K)	8/3/2004
Inquiry with respect to an incorrect Employer Identification Number (EIN) listed on a Form 2553.
INFO 2004-0157(PDF, 15K)	7/26/2004
Taxpayer requesting a late S corporation election.
INFO 2004-0156(PDF, 11K)	8/2/2004
Railroad Retirement Act Tax Status.
INFO 2004-0155(PDF, 14K)	7/20/2004
The revocation of an election made under section 83(b) of the Internal Revenue Code.
INFO 2004-0154(PDF, 17K)	7/21/2004
Application of Income Tax Treaties to Pension Distributions.
INFO 2004-0153(PDF, 15K)	8/20/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0152(PDF, 15K)	8/20/2004
Request to rescind taxpayer’s recent revocation of its election to be an S corporation.
INFO 2004-0151(PDF, 15K)	8/20/2004
Request to rescind taxpayer’s recent revocation of its election to be an S corporation.
INFO 2004-0150(PDF, 14K)	8/20/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0149(PDF, 14K)	8/20/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0148(PDF, 15K)	8/20/2004
Request to rescind Taxpayer’s recent revocation of its election to be an S corporation.
INFO 2004-0147(PDF, 15K)	8/20/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0146(PDF, 10K)	8/20/2004
Request to revoke taxpayer’s election to an S corporation.
INFO 2004-0145(PDF, 14K)	8/20/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0144(PDF, 15K)	8/20/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0143(PDF, 15K)	7/26/2004
Requesting a late S corporation election.
INFO 2004-0142(PDF, 14K)	6/24/2004
Requesting relief in order to establish March 1, 2000, as the effective date for S corporation election.
INFO 2004-0141(PDF, 12K)	8/9/2004
Railroad Retirement Act Tax Status.
INFO 2004-0140(PDF, 11K)	5/14/2004
Railroad Retirement Act Tax Status.
INFO 2004-0139(PDF, 11K)	5/19/2004
Railroad Retirement Act Tax Status.
INFO 2004-0138(PDF, 14K)	8/20/2004
Request to recognize Taxpayer’s election to be an S corporation.
INFO 2004-0137(PDF, 8K)	8/3/2004
Requesting a late S corporation election.
INFO 2004-0136(PDF, 12K)	6/28/2004
Railroad Retirement Act Tax Status.
INFO 2004-0135(PDF, 11K)	4/12/2004
Railroad Retirement Act Tax Status.
INFO 2004-0134(PDF, 14K)	7/20/2004
Request to revoke section 179 election.
INFO 2004-0133(PDF, 11K)	6/25/2004
Railroad Retirement Act Tax Status.
INFO 2004-0132(PDF, 11K)	6/21/2004
Railroad Retirement Act Tax Status.
INFO 2004-0131(PDF, 11K)	5/19/2004
Railroad Retirement Act Tax Status.
INFO 2004-0130(PDF, 12K)	5/19/2004
Railroad Retirement Act Tax Status.
INFO 2004-0129(PDF, 11K)	3/16/2004
Railroad Retirement Act Tax Status.
INFO 2004-0128(PDF, 11K)	3/8/2004
Railroad Retirement Act Tax Status.
INFO 2004-0127(PDF, 9K)	8/3/2004
Correction of the Taxpayer’s name and employer identification number (EIN).
INFO 2004-0126(PDF, 12K)	3/24/2004
Railroad Retirement Act Tax Status.
INFO 2004-0125(PDF, 11K)	7/28/2004
Various issues related to the serial bankruptcies of an individual and his businesses.
INFO 2004-0124(PDF, 12K)	8/4/2004
Questioning of the Internal Revenue Code (the Code) to include operators of dog kennels and their employees as “agricultural labor” for purposes of the Federal Unemployment Tax Act (FUTA). The Code does not classify dog breeding as agricultural, while the Missouri State Tax Commission does. They believe this inconsistent treatment results in additional fees for dog breeders.
INFO 2004-0123(PDF, 9K)	8/9/2004
The tax treatment concerning payments made to automotive service technician employees.
INFO 2004-0122(PDF, 15K)	8/16/2004
Request that the IRS amend the "qualified nonpersonal use vehicles" list in Publication 15-B to include "Highway Commissions and Patrol Superintendent vehicle used for highway purposes."
INFO 2004-0121(PDF, 17K)	7/8/2004
Inquiry regarding refund of taxes paid on seperation pay received from Defense Finance and Accounting Service before the Veterans' Administration determined the Taxpayer was entitled to receive disability pay.
INFO 2004-0120(PDF, 14K)	7/8/2004
Concern over additional income tax attributed to the alternative minimum tax.
INFO 2004-0119(PDF, 15K)	6/18/2004
Questioning of Federal Insurance Contributions Act (FICA) taxes on a retirement payment.
INFO 2004-0118(PDF, 16K)	4/2/2004
The purchase of a boat with intentions to use as a principal residence while paying local sales tax and whether the nondeductibility of the sales taxes for federal income tax purposes results in double taxation.
INFO 2004-0117(PDF, 25K)	3/24/2004
The application of the tax incentives for a renewal community, an empowerment zone, and an enterprise community to a client of a professional employer organization (“PEO”).
INFO 2004-0116(PDF, 15K)	6/1/2004
Requesting a late S corporation election.
INFO 2004-0115(PDF, 25K)	3/29/2004
The reporting and tax treatment of certain refunds (with interest) of retirement contributions made from a qualified defined benefit retirement plan.
INFO 2004-0114(PDF, 20K)	5/13/2004
The determination of an arms length interest rate for inter-company lending by a U.S. corporation to foreign subsidiaries when the laws of the country of the foreign subsidiary set a maximum rate of interest that is lower than the U.S. applicable federal rate (AFR).
INFO 2004-0113(PDF, 14K)	5/28/2004
Inquiry regarding charitable contributions of certain property.
INFO 2004-0112(PDF, 13K)	5/28/2004
Requesting the Commissioner’s consent to revoke an election made under section 179 of the Internal Revenue Code on the Taxpayers federal income tax return for certain property placed in service.
INFO 2004-0111(PDF, 14K)	6/4/2004
Requesting permission to reelect the provisions of section 911 of the Internal Revenue Code for the tax year and subsequent tax years.
INFO 2004-0110(PDF, 15K)	6/1/2004
Requesting a late S election.
INFO 2004-0109(PDF, 18K)	4/29/2004
Request for general information regarding the taxation of supplemental payments.
INFO 2004-0108(PDF, 17K)	4/30/2004
Inquiry regarding capital loss carryovers. Specifically, whether an individual’s capital loss carryover can be carried forward indefinitely.
INFO 2004-0107(PDF, 14K)	5/12/2004
Inquiry regarding entity classification election relief.
INFO 2004-0106(PDF, 15K)	6/1/2004
Requesting a late S election.
INFO 2004-0105(PDF, 10K)	4/21/2004
Requesting relief under Revenue Procedure 2003-43, in order to establish June 27, 2002, as the effective date for your S corporation election.
INFO 2004-0104(PDF, 13K)	3/29/2004
Requesting automatic relief to establish a taxable year for S corporation election.
INFO 2004-0103(PDF, 13K)	3/30/2004
Requesting automatic relief to establish a taxable year for S corporation election.
INFO 2004-0102(PDF, 13K)	3/30/2004
Requesting automatic relief to establish a taxable year for S corporation election.
INFO 2004-0101(PDF, 17K)	4/14/2004
Inquiry regarding the documentation requirements for an international organization claiming exemption from U.S. withholding tax. Generally, payments to an international organization from any source within the United States are exempt from tax pursuant to section 892(b) and §1.892-6T and exempt from withholding pursuant to §1.1441-8(d).
INFO 2004-0100(PDF, 15K)	3/29/2004
Requesting a late S corporation election.
INFO 2004-0099(PDF, 11K)	5/28/2004
Requesting a late S election.
INFO 2004-0098(PDF, 14K)	6/1/2004
Requesting a late S election.
INFO 2004-0097(PDF, 15K)	6/1/2004
Requesting a late S election.
INFO 2004-0096(PDF, 8K)	5/28/2004
Requesting permission to file an S corporation election.
INFO 2004-0095(PDF, 14K)	6/3/2004
Request to recognize Taxpayer's election to be an S corporation.
INFO 2004-0094(PDF, 17K)	4/6/2004
Refund claim for taxes paid under Federal Insurance Contribuitions Act ( FICA ).
INFO 2004-0093(PDF, 14K)	6/18/2004
Request for an official statement stipulating qualifications to be a donee of a conservation easement.
INFO 2004-0092(PDF, 14K)	5/26/2004
Local government taxation of a Taxpayer's federal pension plan account and the authority of their city to tax their account under federal laws.
INFO 2004-0091(PDF, 17K)	6/4/2004
Inquiry concerning an article in the New York Times on March 21, 2004 regarding a dispute involving tuition payments for a Jewish Day school.
INFO 2004-0090(PDF, 15K)	4/29/2004
Deductibility of private school tuition as a medical care expense.
INFO 2004-0089(PDF, 24K)	5/4/2004
Rules concerning the deferral of crop insurance proceeds. Specifically, the rule that if a taxpayer receives both federal crop insurance and private crop insurance proceeds as a result of destruction or damage to crops, the taxpayer cannot defer one type of insurance proceeds but not the other type if those amounts are attributable to crops representing a single trade or business.
INFO 2004-0088(PDF, 27K)	4/30/2004
Proper tax treatment of losses incurred by investors and whether the “frozen deposit rule” applies to interest income reported on Form 1099-INT, and whether taxpayers can deduct the investment losses as capital or casualty losses.
INFO 2004-0087(PDF, 23K)	4/8/2004
Determining whether certain workers are independent contractors or employees.
INFO 2004-0086(PDF, 20K)	6/24/2004
Request for a private letter ruling about the income tax consequences of long-term care insurance premium payments.
INFO 2004-0085(PDF, 17K)	5/27/2004
Refund claim for Federal Insurance Contributions Act (FICA) tax.
INFO 2004-0084(PDF, 8K)	4/4/2004
Exclusion of night school students in the definition of a full-time student in § 1.151-3(b) of the Income Tax Regulations.
INFO 2004-0083(PDF, 12K)	3/30/2004
A raise resulting in less pay to an employee due to more money withheld for tax purposes by employer.
INFO 2004-0082(PDF, 27K)	3/17/2004
Proper tax treatment of losses incurred by investors.
INFO 2004-0081(PDF, 12K)	3/22/2004
The taxability of certain payments to the shrimp industry in South Carolina under the Consolidated Appropriations Resolution, 2003, Pub. L. No. 108-7, 117 Stat. 11 (the “Act”). Section 501(d)(1) of the Act provides for economic assistance to the shrimp industry in South Carolina and other states.
INFO 2004-0080(PDF, 35K)	2/27/2004
Income tax information concerning non-U.S. military members and their spouses who reside in the United States under a North Atlantic Treaty Organization (NATO) visa.
INFO 2004-0079(PDF, 16K)	3/9/2004
Rev. Proc. 2001-34, which relates to the tax credit for solid synthetic fuels produced from coal (§ 29 of the Internal Revenue Code).
INFO 2004-0078(PDF, 14K)	3/17/2004
Requesting automatic relief in order to establish an S corporation election.
INFO 2004-0077(PDF, 13K)	3/17/2004
Request for late S corporation relief.
INFO 2004-0076(PDF, 14K)	3/17/2004
Requesting automatic relief in order to establish S corporation election.
INFO 2004-0075(PDF, 9K)	3/17/2004
Requesting to revoke an S corporation election.
INFO 2004-0074(PDF, 15K)	1/7/2004
Requesting automatic relief under Revenue Procedure 97-48, in order to establish 1993 as the effective taxable year for your S corporation election.
INFO 2004-0073(PDF, 13K)	1/7/2004
Relief in order to establish S corporation status effective as of the date of incorporation.
INFO 2004-0072(PDF, 13K)	1/7/2004
Requesting a private letter ruling in order to be considered for late S corporation relief under § 1362(b)(5) of the Internal Revenue Code.
INFO 2004-0071(PDF, 13K)	1/7/2004
Requesting relief under Revenue Procedure 2003-43, in order to establish January 18, 2001, as the effective date for your S corporation election.
INFO 2004-0070(PDF, 12K)	3/1/2004
Request to revoke S election.
INFO 2004-0068(PDF, 9K)	2/6/2004
Proper tax treatment of damages received from a settlement award.
INFO 2004-0067(PDF, 8K)	12/16/2003
Inquiries about the proposed revenue procedure (Notice 2002-79) that will modify and supersede Rev. Proc. 71-21, 1971-2 C.B. 249.
INFO 2004-0066(PDF, 14K)	12/2/2003
The application of the special depreciation allowance to farming businesses.
INFO 2004-0065(PDF, 15K)	11/7/2003
The procedures that employers may use to obtain the necessary employee supporting statements for an employer’s refund claim of employee taxes. Specifically, whether an employer can request and obtain the necessary “written statement” from an employee, as required under Procedures and Administration Regulation section 31.6402(a)-2(a)(2), from an employee in an electronic submission (e.g., e-mail).
INFO 2004-0064(PDF, 54K)	10/28/2003
Requesting permission to make a late election under section 179 of the Internal Revenue Code for certain property on a 1999 federal income tax return filed on April 15, 2000.
INFO 2004-0063(PDF, 60K)	10/20/2003
The tax treatment of reimbursements received for transportation and meal expenses.
INFO 2004-0062(PDF, 14K)	10/14/2003
Section 457(b) of the Internal Revenue Code (the Code) governing the taxation of amounts deferred into eligible deferred compensation plans sponsored by tax-exempt employers or by state or local governments. She asked that th
INFO 2004-0061(PDF, 50K)	9/17/2003
The treatment of project rental assistance contract (PRAC) payments under section 202 of the National Housing Act when used with projects receiving the low-income housing tax credit under section 42 of the Internal Revenue Code.
INFO 2004-0060(PDF, 15K)	9/8/2003
Obtaining a refund of FICA taxes deducted from a retirement payment made in 2001 and which taxes were paid to the IRS.
INFO 2004-0059(PDF, 54K)	7/2/2003
Permission to deduct currently under § 174(a) of the Internal Revenue Code research and experimental ( R&E) expenditures, effective for the first taxable year ending 2002. The following information is being provided pursuant to section 2.04 of Rev. Proc. 2003-1, 2003-1 I.R.B. 1, 7 (January 6, 2003).
INFO 2004-0058(PDF, 15K)	3/28/2003
Inquiry as to whether or not an employee formerly covered by a state or local retirement system may pay Federal Insurance Contributions Act (FICA) tax retroactively to obtain social security coverage for years in which the employee participated in the state retirement system.
INFO 2004-0057(PDF, 59K)	3/25/2003
Railroad Retirement Act Tax Status.
INFO 2004-0056(PDF, 58K)	3/25/2003
Request for ruling with respect to bonds for a facility and application of § 1.141-7(f)(1) of the Income Tax Regulations.
INFO 2004-0055(PDF, 51K)	3/21/2003
The availability of the relief from certain federal tax obligations, such as postponement of the time for filing an income tax return and payment of tax, provided by section 7508 of the Internal Revenue Code. This information relates to United States merchant mariners who serve aboard vessels under the operational control of the Department of Defense.
INFO 2004-0054(PDF, 16K)	3/5/2004
INFO 2004-0053(PDF, 8K)	3/1/2004
Requesting a late S election.
INFO 2004-0052(PDF, 15K)	3/1/2004
Requesting a late S election.
INFO 2004-0051(PDF, 13K)	3/1/2004
Requesting relief in order to establish, May 28, 2002 as the effective taxable year for an S corporation election.
INFO 2004-0050(PDF, 16K)	2/25/2004
Requested information about the disabled access credit under section 44 of the Internal Revenue Code (Code) and the architectural and transportation barrier removal deduction under section 190 of the Code.
INFO 2004-0049(PDF, 13K)	3/1/2004
According to the facts provided, the company revoked its S election effective January 1, 2001. We believe you wish to revoke the company's S election by filing a revocation effective as of December 16, 1988.
INFO 2004-0048(PDF, 16K)	2/13/2004
Requesting permission to expense currently under § 174(a) of the Internal Revenue Code research and experimental (R&E) expenditures, effective for the taxable year ending December 31, 2003.
INFO 2004-0047(PDF, 9K)	3/2/2004
Requesting late S corporation relief under section 1362(b)(5) of the Internal Revenue Code, seeking an effective date of January 1, 2002.
INFO 2004-0046(PDF, 18K)	3/31/2004
Requesting guidance on the income tax consequences of local law enforcement officers’ use of unmarked law enforcement vehicles.
INFO 2004-0044(PDF, 14K)	10/1/2003
Requesting relief in order to establish 1999 as the effective taxable year for its S corporation election. Automatic late S corporation relief is unavailable under Revenue Procedure 97-48 because Taxpayer’s 1999 and 2000 returns were not timely filed.
INFO 2004-0043(PDF, 23K)	3/31/2004
Taxpayer maintains that the incorrect amount of proceeds was reported by the transfer agent to him (as well as the Service) on the sale of a certain fractional share of stock previously held in a dividend reinvestment plan. The essence of his complaint is that gross proceeds from that disposition, as opposed to net proceeds, were reported on the Form 1099-B information return.
INFO 2004-0042(PDF, 15K)	2/6/2004
Requesting a late S election effective November 15, 1999.
INFO 2004-0041(PDF, 14K)	2/6/2004
Regarding a revocation of an S election.
INFO 2004-0040(PDF, 18K)	2/6/2004
Requesting late QSST election relief pursuant Rev. Proc. 98-55. Relief is not available for the taxpayer pursuant to Rev. Proc. 98-55 as well as under Rev. Proc. 2003-43. Rev. Proc. 98-55 is not applicable because the trust does not meet the requirements for eligibility found in Section 4.02. Furthermore, relief is also not available under Rev. Proc. 2003-43 due to the trust’s failure to meet the eligibility requirements under Section 4.02.
INFO 2004-0039(PDF, 14K)	2/6/2004
Requesting late S corporation election relief.
INFO 2004-0038(PDF, 8K)	2/6/2004
Requesting late S corporation election relief as well as relief to file a late entity classification election for the above named taxpayer.
INFO 2004-0037(PDF, 14K)	2/4/2004
Requesting late S corporation election relief.
INFO 2004-0036(PDF, 14K)	2/3/2004
Requested recognition of Taxpayer’s election to be an S corporation effective November 9, 2001.
INFO 2004-0035(PDF, 17K)	3/31/2004
General information letter in response to questions about an offer for on-line tax preparation and electronic filing services to employers who wish to provide these services as a benefit to their employees.
INFO 2004-0034(PDF, 15K)	1/13/2004
Requesting relief in order to establish April 27, 1998, as the effective date for your election to be a qualified subchapter S trust. Automatic late election relief is unavailable under Revenue Procedure 2003-43 because more than 24 months have passed since the original due date of the election.
INFO 2004-0033(PDF, 21K)	1/13/2004
Issues: Whether there is an unauthorized disclosure under I.R.C. § 6103, when a nondesignee1 third party: (1) submits a completed and signed Form 2290 and accompanying Schedule 1 with cash or check payment to a Service employee; (2) the employee acknowledges the receipt thereof by stamping Schedule 1; and (3) returns the original (stamped copy) of Form 2290, Schedule 1 and a copy of Form 2290 back to the third party?
INFO 2004-0032(PDF, 13K)	3/31/2004
Explanation about the tax treatment of a severance pay repayment.
INFO 2004-0031(PDF, 15K)	1/13/2004
Requesting relief in order to establish August 4, 2000, as the effective taxable year for your S corporation election.
INFO 2004-0030(PDF, 12K)	1/20/2004
Request to recognize Taxpayer’s revocation of its election to be an S corporation, effective November 2, 2000.
INFO 2004-0029(PDF, 14K)	1/20/2004
Request to recognize Taxpayer’s election to be an S corporation, effective January 25, 2000.
INFO 2004-0028(PDF, 17K)	3/31/2004
Request for a private letter ruling regarding an award of attorneys’ fees under the Uniform Relocation Assistance and Real Property Acquisition Policies Act (URA), 42 U.S.C. §§ 4601-55. In March 2003, the taxpayer requested a ruling that attorneys’ fees recovered by pro bono counsel for vindicating the constitutional rights of these clients not be included in the gross income of these clients under § 61(a) of the Internal Revenue Code. Relying on well-established legal principles, the IRS advised the taxpayer that it would rule adversely; subsequently, the taxpayer withdrew its request.
INFO 2004-0027(PDF, 14K)	1/7/2004
Requesting automatic relief in order to establish September 19, 2001, as the effective date for your S corporation election.
INFO 2004-0026(PDF, 9K)	1/7/2004
Requesting relief for a late S corporation election, for an effective date of September 9, 2002.
INFO 2004-0025(PDF, 14K)	1/7/2004
Requesting late S corporation relief for an effective date of April 4, 2001.
INFO 2004-0024(PDF, 11K)	1/7/2004
Requesting relief for a late S corporation election, for an effective date of September 4, 2002.
INFO 2004-0023(PDF, 13K)	1/7/2004
Requesting relief in order to establish October 5, 2000, as the effective date for your S corporation election.
INFO 2004-0022(PDF, 14K)	1/7/2004
Request for late S corporation relief for the 1999 taxable year. Your account currently reflects S corporation status effective as of the 2000 taxable year. Although your 1999 tax return was filed using Form 1120S, the Internal Revenue Service sent a notice to you about the missing Form 2553 within six months of receiving the return which deems you ineligible for automatic relief under Revenue Procedure 97-48. Although we are unable to grant automatic relief, this letter provides information relating to rectifying your situation.
INFO 2004-0021(PDF, 13K)	1/7/2004
Requesting relief in order to establish July 1, 2000, as the effective date for your S corporation election.
INFO 2004-0020(PDF, 9K)	1/27/2004
Requesting relief in order to establish June 14, 2001 (date of incorporation), as the effective date for your S corporation election. Based on the information provided, a Form 2553 was submitted in a timely manner, but you failed to receive an acceptance notice from the Internal Revenue Service.
INFO 2004-0019(PDF, 11K)	3/31/2004
Request for late S corporation election relief to be effective as of the 1996 taxable year (year of incorporation).
INFO 2004-0018(PDF, 9K)	1/7/2004
Request for late S corporation election relief to be effective as of the 1999 taxable year (year of incorporation).
INFO 2004-0017(PDF, 13K)	1/7/2004
Requesting relief in order to establish September 27, 2000, as the effective date for your S corporation election.
INFO 2004-0016(PDF, 13K)	1/7/2004
Requesting relief in order to establish May 5, 1997, as the effective date for your S corporation election.
INFO 2004-0015(PDF, 11K)	1/7/2004
Requesting relief for a late S corporation election, to be effective as of March 20, 2001.
INFO 2004-0014(PDF, 13K)	1/7/2004
Requesting automatic late S corporation relief.
INFO 2004-0013(PDF, 13K)	1/7/2004
Requesting relief under Revenue Procedure 97-48, in order to establish June 1, 1998, as the effective date for your S corporation election.
INFO 2004-0012(PDF, 15K)	1/8/2004
Request for tax-exempt status.
INFO 2004-0011(PDF, 13K)	1/7/2004
Requesting relief under Revenue Procedure 97-48, in order to establish July 1, 2000, as the effective date for your S corporation election.
INFO 2004-0010(PDF, 15K)	12/19/2003
Request to defer and amortize research and experimental expenditures (R&E expenditures) relating to the design, manufacture, and testing of vehicles under section 174(b) of the Internal Revenue Code.
INFO 2004-0009(PDF, 8K)	12/9/2003
This refers to the letter dated January 11, 2002, that we issued to X requested the advice contained in the letter on behalf of your office. That letter was published as a general information letter (GENIN-156710-01). Upon further consideration, we revoke that letter.
INFO 2004-0008(PDF, 13K)	11/6/2003
We provide guidance through a “letter ruling” that interprets and applies the tax laws to the taxpayer’s specific set of facts. Rev. Proc. 2003-1, 2003-1 I.R.B. 1, sets forth standards and guidelines that a taxpayer must meet before we can issue such a ruling letter. We are unable to rule on the above matter, because your request does not meet the requirements of this revenue procedure.
INFO 2004-0007(PDF, 15K)	3/31/2004
Request for information regarding low income housing tax-credit partnerships.
INFO 2004-0006(PDF, 43K)	6/12/2003
Regarding the proposed revenue procedure (Notice 2002-79) that, if finalized, will modify and supersede Rev. Proc. 71-21, 1971-2 C.B. 249.
INFO 2004-0005(PDF, 15K)	10/27/2003
Requesting a late S election.
INFO 2004-0004(PDF, 11K)	10/24/2003
Requesting late S corporation relief.
INFO 2004-0003(PDF, 62K)	9/25/2003
Request for general information regarding a church's reporting and withholding obligations with respect to raffle prize proceeds under the circumstances described below. You indicate that the church, which is exempt from federal income tax under section 501(c)(3) of the Internal Revenue Code, conducts the raffle as a means of raising funds for its exempt activities.
INFO 2004-0002(PDF, 15K)	9/8/2003
Taxpayer Request regarding refunds of FICA taxes on faculty retirement incentive payments as arbitrary, capricious, and discriminatory.
INFO 2004-0001(PDF, 26K)	8/27/2003
Request for an explanation of the federal tax treatment of payments made to Oregon fishers whose bids are accepted in the Pacific Coast Groundfish Fishing Capacity Reduction Program (the Program).

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2004 Chief Counsel'sWritten Determinations

2004 Chief Counsel's
Written Determinations