| 200409040(PDF, 150K) |
2/26/2004 |
| Requesting advance approval of your grant making procedures pursuant to the provisions of section 4945 of the Code. |
| 200409039(PDF, 112K) |
2/26/2004 |
| Requested a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Code . |
| 200409038(PDF, 44K) |
2/27/2004 |
| Requesting rulings under section 29 of the Code. |
| 200409037(PDF, 21K) |
2/27/2004 |
| Requests an extension of time under Treas. Reg. § 301.9100-3 until Date 3 to attach to its U.S. income tax return for the tax year ended on Date 2 documents as provided under § 1.1503-2(g)(2)(vii)(B). |
| 200409036(PDF, 18K) |
2/27/2004 |
| Requests an extension of time under Treas. Reg. § 301.9100-3 to file an agreement described in § 1.1503-2(g)(2)(i) for the tax year ended on Date A (the 2(g)(2)(i) agreement). |
| 200409035(PDF, 20K) |
2/27/2004 |
| Requests an extension of time under Treas. Reg. § 301.9100-3 to make the election provided by the Code § 953(d), in accordance with Notice 89-79, 1989-2 C.B. 392, 393, to be treated as a domestic corporation for U.S. tax purposes for the tax year ended on Date A. |
| 200409034(PDF, 22K) |
2/27/2004 |
| Requesting rulings on certain federal income tax consequences of a completed transaction. |
| 200409033(PDF, 42K) |
2/27/2004 |
| Request submitted by your representative on May 23, for various rulings for Corporation. |
| 200409032(PDF, 18K) |
2/27/2004 |
| Requesting a ruling under § 1362(b)(5) of the Code. |
| 200409031(PDF, 18K) |
2/27/2004 |
| Requesting a letter ruling under § 301.9100-3 of the Procedure and Administration Regulations to extend the time to make the election provided under section 168(k)(2)(C)(iii) of the Code, not to deduct the 30-percent additional first year depreciation for qualified property placed in service in Taxpayer’s taxable year that included September 11, 2001. |
| 200409030(PDF, 27K) |
2/27/2004 |
| 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 Parent to file an election under § 1.1502-20T(i)(4) of the Income Tax Regulations to apply the provisions of §1.337(d)-2T to determine the allowable losses sustained upon the sale of the stock of certain subsidiary members of its consolidated group during the taxable year ending Date A. |
| 200409029(PDF, 20K) |
2/27/2004 |
| Requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations, that X be granted an extension of time to elect to be a partnership under section 301.7701-3(c). |
| 200409028(PDF, 45K) |
2/27/2004 |
| Requesting an extension of time pursuant to § 2642(g) of the Code and § 301.9100-3 of the Procedure and Administration Regulations to make allocations of your GST tax exemptions. |
| 200409027(PDF, 38K) |
2/27/2004 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. Additional information was received in letters dated October 24, 2003 and November 14, 2003. The information submitted is substantially as set forth below. |
| 200409026(PDF, 40K) |
2/27/2004 |
| This is in response to your letter dated August 6, and subsequent correspondence, in which you Request an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Taxpayer 1’s and Taxpayer 2’s GST tax exemptions to transfers made to irrevocable trusts. |
| 200409025(PDF, 28K) |
2/27/2004 |
| Requesting a ruling concerning two factors under Article 24 (Limitation on Benefits) of the United States-Luxembourg income tax treaty . |
| 200409024(PDF, 42K) |
2/27/2004 |
| Requesting rulings under the Code §§ 368 and 355. Additional information was submitted in a letter dated November 6, 2003. The information submitted in your letters is summarized below. |
| 200409023(PDF, 23K) |
2/27/2004 |
| Requesting a ruling under § 1362(f) of the Code. |
| 200409022(PDF, 28K) |
2/27/2004 |
| This responds to a letter from the Taxpayer's authorized representative dated A, as supplemented by a letter dated B, in which you 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 Code of 1986, as amended , pursuant to the United States-Ireland income tax convention ("Treaty"). |
| 200409021(PDF, 24K) |
2/27/2004 |
| Request dated May 2, for supplemental rulings with respect to a private letter ruling dated April 24, 2002, (PLR-124344-01) (the "Prior Letter Ruling") involving the federal income tax consequences of a proposed transaction (the "Proposed Transaction"). Additional information was submitted in letters dated October 21, October 25, October 28, and November 3, 2003. Except as modified herein, the facts and representations set forth in the Prior Ruling are still valid. The taxpayers consummated the Proposed Transaction on Date 1. The legend abbreviations, factual summary, and representations appearing in the Prior Letter Ruling are hereby incorporated by reference unless otherwise indicated. |
| 200409020(PDF, 24K) |
2/27/2004 |
| Request dated May 2, for supplemental rulings with respect to a private letter ruling dated April 24, 2002, (PLR-124344-01) (the "Prior Letter Ruling") involving the federal income tax consequences of a proposed transaction (the "Proposed Transaction"). Additional information was submitted in letters dated October 21, October 25, October 28, and November 3, 2003. Except as modified herein, the facts and representations set forth in the Prior Ruling are still valid. The taxpayers consummated the Proposed Transaction on Date 1. The legend abbreviations, factual summary, and representations appearing in the Prior Letter Ruling are hereby incorporated by reference unless otherwise indicated. |
| 200409019(PDF, 24K) |
2/27/2004 |
| Request dated May 2, for supplemental rulings with respect to a private letter ruling dated April 24, 2002, (PLR-124344-01) (the "Prior Letter Ruling") involving the federal income tax consequences of a proposed transaction (the "Proposed Transaction"). Additional information was submitted in letters dated October 21, October 25, October 28, and November 3, 2003. Except as modified herein, the facts and representations set forth in the Prior Ruling are still valid. The taxpayers consummated the Proposed Transaction on Date 1. The legend abbreviations, factual summary, and representations appearing in the Prior Letter Ruling are hereby incorporated by reference unless otherwise indicated. |
| 200409018(PDF, 18K) |
2/27/2004 |
| Requesting a ruling supplementing the rulings previously issued in PLR-100611-02, published as PLR 200239022 (the Original Letter Ruling). |
| 200409017(PDF, 16K) |
2/27/2004 |
| Requesting relief under § 1362(b)(5) of the Code. |
| 200409016(PDF, 23K) |
2/27/2004 |
| Requesting a ruling that X and Y 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 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. |
| 200409015(PDF, 27K) |
2/27/2004 |
| 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 Parent to make an election under § 1.1502-20T(i)(4) of the Income Tax Regulations, to apply the provisions of § 1.337(d)-2T for Parent’s consolidated taxable year ending on Date A (sometimes hereinafter referred to as the “Election”). |
| 200409014(PDF, 20K) |
2/27/2004 |
| Requesting a ruling that it 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 treat X1 as a disregarded entity for federal tax purposes. |
| 200409013(PDF, 26K) |
2/27/2004 |
| Requesting a ruling that X be granted an extension of time pursuant to §301.9100-3 of the Procedure and Administration Regulations in which to elect to be treated as a disregarded entity under §301.7701-3(c). In addition, Y requests an extension of time, for purposes of §1.897-2(g)(1)(ii)(A) of the Income Tax Regulations, for X to obtain a statement described in §1.897-2(h)(1) from Z that the stock interest in Z is not a U.S. real property interest. |
| 200409012(PDF, 32K) |
2/27/2004 |
| This letter responds to the letter dated February 5, 2003 and related correspondence, written on behalf of X, requesting a ruling under § 1362(f) of the Code for inadvertent termination of S corporation election, and an extension of time under § 301.9100-1 and '301.9100-3 of the Procedure and Administration Regulations to file an entity classification election under § 301.7701-3(c). |
| 200409011(PDF, 23K) |
2/27/2004 |
| Requesting a ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Code. |
| 200409010(PDF, 39K) |
2/27/2004 |
| Request for ruling submitted on the behalf of X Corp, a corporation organized under the laws of State, concerning the accrual of life insurance proceeds. X Corp is an "S corporation" as that term is defined in § 1361(a) of the Code. X Corp uses the accrual method of accounting. |
| 200409009(PDF, 90K) |
2/27/2004 |
| This letter responds to a letter, dated May 19, submitted on behalf of A by its authorized representative, requesting rulings under § 29 and § 702 of the Code. |
| 200409008(PDF, 28K) |
2/27/2004 |
| Requesting rulings concerning the federal income tax consequences of a proposed transaction. The information submitted in that and subsequent correspondence is summarized below. |
| 200409007(PDF, 32K) |
2/27/2004 |
| This letter responds to a letter, dated May 8, submitted on behalf of A by its authorized representative, requesting a ruling under § 29 of the Internal Revenue |
| 200409006(PDF, 18K) |
2/27/2004 |
| Requesting a ruling under § 1362(b)(5) of the Code. |
| 200409005(PDF, 18K) |
2/27/2004 |
| Requesting permission for Corporation to revoke its election under § 41(c)(4) of the Code. |
| 200409004(PDF, 48K) |
2/27/2004 |
| This is in response to your letter dated March 20, and subsequent submissions, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to allocate Taxpayers' GST exemption to certain trusts. |
| 200409003(PDF, 58K) |
2/27/2004 |
| This is in response to your correspondence dated January 29, requesting a ruling concerning the income, gift, and generation-skipping transfer tax consequences of the proposed severance and modification of Trust under § 1001, 2501, and 2601 of the Code. |
| 200409002(PDF, 31K) |
2/27/2004 |
| This is in response to your letter dated September 10, on behalf of Decedent’s estate, requesting an extension of time under § 2642(g) of the Code and § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Decedent’s GST exemption. |
| 200409001(PDF, 76K) |
2/27/2004 |
| Issue: Whether certain redemptions of stock (made in order to pay the tax owed on a prior gift of stock) should be treated as not essentially equivalent to dividends or as sales or exchanges under section 302(b)(1) of the Code. |
| 200408035(PDF, 566K) |
11/25/2003 |
| Request for rulings that X's proposed grant for housing will further its exempt purposes under § 501(c)(3) of the Internal Revenue Code and will not result in unrelated business taxable income or liability under chapter 42. |
| 200408034(PDF, 474K) |
11/24/2003 |
| Request for rulings that X's proposed grants for various public works will further its exempt purposes under § 501(c)(3) of the Internal Revenue code and will not result in unrelated business taxable income or liability under chapter 42. |
| 200408033(PDF, 191K) |
11/24/2003 |
| Request for rulings that X's proposed grants for various public works will further its exempt purposes under § 501(c)(3) of the Internal Revenue code and will not result in unrelated business taxable income or liability under chapter 42. |
| 200408032(PDF, 62K) |
11/26/2003 |
| Request concerning the prepayment of an exempt loan upon termination of an employee stock ownership plan, and also concerning the allocation of any remaining surplus shares of Company D’s common stock. |
| 200408031(PDF, 106K) |
11/25/2003 |
| Ruling request regarding termination of a trust, under § 644(d)(2) and 644(d)(3) of the Internal Revenue Code. |
| 200408030(PDF, 131K) |
2/20/2004 |
| This Chief Counsel Advice responds to your request that we consider whether the information and legal analysis submitted by the taxpayers’ representative affects our conclusion in an earlier Field Service Advice, FSA 200108003. |
| 200408029(PDF, 72K) |
2/20/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200408028(PDF, 73K) |
2/20/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200408027(PDF, 90K) |
2/20/2004 |
Issues: - Was the transfer of Z’s Product A and Product B United States assets voluntary?
- Were Z’s Product A and Product B United States assets converted for purposes of § 1033(a) of the Internal Revenue Code?
|
| 200408026(PDF, 126K) |
2/20/2004 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to file the election agreement described in § 1.1503-2(g)(2)(i), and the annual certification described § 1.1503-2(g)(2)(vi)(B) in accordance with Schedule A, which is attached and made a part of this ruling letter. |
| 200408025(PDF, 59K) |
2/20/2004 |
| 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 Taxpayer's generation-skipping transfer exemption. |
| 200408024(PDF, 81K) |
2/20/2004 |
| 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. |
| 200408023(PDF, 40K) |
2/20/2004 |
| Requesting that the Service grant X an extension of time pursuant to § 301.9100 of the Procedure and Administration Regulations to file a Form 8832, Entity Classification Election, to elect under § 301.7701-3 to be a partnership for federal tax purposes effective d1. |
| 200408022(PDF, 34K) |
2/20/2004 |
| Requesting an extension of time for LLC to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be treated as an association taxable as a corporation. |
| 200408021(PDF, 47K) |
2/20/2004 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200408020(PDF, 36K) |
2/20/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200408019(PDF, 33K) |
2/20/2004 |
| Requesting permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200408018(PDF, 82K) |
2/20/2004 |
| Requesting rulings under § 29 and 702 of the Internal Revenue Code. |
| 200408017(PDF, 49K) |
2/20/2004 |
| Requesting rulings under § 1362(d)(3) and 1375(a) of the Internal Revenue Code. |
| 200408016(PDF, 34K) |
2/20/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200408015(PDF, 134K) |
2/20/2004 |
| Requesting a ruling concerning the federal income, gift, and estate tax consequences of the creation of a trust. |
| 200408014(PDF, 102K) |
2/20/2004 |
| Requested rulings on behalf of Decedent's estate (Estate) and Decedent's irrevocable Trust (Trust) concerning an extension of time pursuant to § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations to allocate Decedent's available generation-skipping transfer exemption to transfers to an irrevocable trust, and the GST tax consequences of severing the trust into two separate trusts pursuant to § 2642(a)(3). |
| 200408013(PDF, 35K) |
2/20/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200408012(PDF, 32K) |
2/20/2004 |
| Requesting permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200408011(PDF, 40K) |
2/20/2004 |
| Requesting relief for inadvertent invalid subchapter S election under § 1362(f) of the Internal Revenue Code. |
| 200408010(PDF, 82K) |
2/20/2004 |
| Requesting rulings under § 29 and 702 of the Internal Revenue Code. |
| 200408009(PDF, 126K) |
2/20/2004 |
| Requesting rulings as to the federal income tax consequences of certain proposed transactions. |
| 200408008(PDF, 76K) |
2/20/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200408007(PDF, 75K) |
2/20/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200408006(PDF, 102K) |
2/20/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200408005(PDF, 85K) |
2/20/2004 |
| 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 allocations of Generation-Skipping Transfer exemption. |
| 200408004(PDF, 100K) |
2/20/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200408003(PDF, 53K) |
2/20/2004 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations for Taxpayer to file an application for certification of historic status with the United States Department of Interior for purposes of § 47(a)(2) of the Internal Revenue Code. |
| 200408002(PDF, 92K) |
2/20/2004 |
| Request submitted on behalf of Distributing for rulings on certain federal income tax consequences of a proposed transaction. |
| 200408001(PDF, 35K) |
2/20/2004 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to file an agreement described in § 1.1503-2(g)(2)(i) for each dual consolidated loss incurred by Entity in tax years 1, 2, 3 and 4; and to file a separate annual certification described in § 1.1503-2(g)(2)(iv)(B) for tax years 2, 3 and 4 with respect to the dual consolidated loss incurred in the previous taxable year, or years. |
| 200407025(PDF, 150K) |
11/17/2003 |
| Request for a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200407024(PDF, 217K) |
11/18/2003 |
| Ruling request for an extension of an additional five years from the end of the five year period provided under § 4943(c)(6) of the Internal Revenue Code in which to dispose of certain excess business holdings. |
| 200407023(PDF, 145K) |
11/17/2003 |
| Request for a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200407022(PDF, 252K) |
11/18/2003 |
| Request for a ruling concerning the federal income tax treatment under Internal Revenue Code 414(h)(2) of certain contributions§ to Plan X. |
| 200407021(PDF, 298K) |
11/19/2003 |
| Request a letter ruling dealing with the requirements of § 204(h) of the Employee Retirement Income Security Act of 1974, as amended (EMPLOYEE RETIREMENT INCOME SECURITY ACT). |
| 200407020(PDF, 47K) |
2/13/2004 |
| Issue: What is the proper procedure for disallowing the additional child tax credit under § 24(d) of the Internal Revenue Code when the Internal Revenue Service has issued a refund or when the Service has frozen the refund? |
| 200407019(PDF, 53K) |
2/13/2004 |
| Issue: Must the Internal Revenue Service provide an Internal Revenue Code. § 6330 notice and right to a hearing before serving a levy to collect an IRC § 6673(a)(1) |
| 200407018(PDF, 131K) |
2/13/2004 |
| Issue: Is Painting, for which an estate tax marital deduction was claimed and allowed on the estate tax return (Form 706) filed by the estate of Decedent’s spouse, H, includible in Decedent’s gross estate pursuant to the doctrine of duty of consistency? |
| 200407017(PDF, 59K) |
2/13/2004 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200407016(PDF, 35K) |
2/13/2004 |
| Requesting a ruling that a qualified terminable interest property election made on Decedent’s federal estate tax return be considered null and void and that the property subject to the qualified terminable interest property election will not be includible in the gross estate of Spouse under § 2044 of the Internal Revenue Code. |
| 200407015(PDF, 57K) |
2/13/2004 |
Issues: (1) Where Corporation A has an overpayment from Year 1, and in Year 2, Corporation A merges with Corporation B, with Corporation B surviving the merger; whether interest payable on Corporation A’s Year 1 overpayment may be netted against interest owed on Corporation B’s Year 4 underpayment.
(2) Whether interest payable on Corporation A’s Year 1 overpayment may be netted against interest owed on Corporation D’s Year 4 underpayments.
(3). Where Corporation B files a consolidated return with an affiliated group for Year 6 and Year 7, and both years have underpayments, whether interest payable on Corporation A’s Year 1 overpayment may be netted against interest owed on the consolidated return’s Year 6 and Year 7 underpayments. (4) Whether interest payable on Corporation C’s Year 4 overpayment may be netted against interest owed on Corporation D’s Year 4 underpayments.
(5) Where Corporation C files a consolidated return with an affiliated group for Year 6 and Year 7, and both years have underpayments, whether interest payable on Corporation C’s Year 4 overpayment may be netted against interest owed on the consolidated return’s Year 6 and Year 7 underpayments. |
| 200407014(PDF, 63K) |
2/13/2004 |
| Issue: Whether the worker under the circumstances described below, is an employee of the firm for Federal employment tax purposes. |
| 200407013(PDF, 81K) |
2/13/2004 |
| Request for rulings regarding certain federal income tax consequences of a proposed transaction |
| 200407012(PDF, 65K) |
2/13/2004 |
| Trust 1, Trust 2, Corporation 1, Corporation 2 and Corporation 3 requesting relief under § 1362(f). |
| 200407011(PDF, 51K) |
2/13/2004 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200407010(PDF, 39K) |
2/13/2004 |
| Requesting a ruling that A’s loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200407009(PDF, 39K) |
2/13/2004 |
| Requesting a ruling that A’s loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200407008(PDF, 77K) |
2/13/2004 |
| Rulings were requested as to the federal income tax consequences of a proposed transaction. |
| 200407007(PDF, 81K) |
2/13/2004 |
| Requested rulings concerning the Federal income tax consequences of a proposed transaction. |
| 200407006(PDF, 89K) |
2/13/2004 |
| Requesting rulings under § 1361, 2701, 2703, and 2704 of the Internal Revenue Code |
| 200407005(PDF, 85K) |
2/13/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to allocate Husband's GST exemption to Trust, and a determination that a previous allocation to Trust is void or ineffective. |
| 200407004(PDF, 33K) |
2/13/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200407003(PDF, 81K) |
2/13/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to allocate Settlor's GST exemption to Trust, and a determination that a previous allocation to Trust is deemed void or ineffective. |
| 200407002(PDF, 49K) |
2/13/2004 |
| Requesting rulings regarding the classification of Trust as a liquidating trust under § 301.7701-4(d) of the Procedure and Administration Regulations and that Trust will be a grantor trust and the Beneficiaries of Trust will be treated as owners of Trust under § 671 and 677. |
| 200407001(PDF, 126K) |
2/13/2004 |
| Requesting rulings under § 29 and 702 of the Internal Revenue Code. |
| 200406056(PDF, 261K) |
11/13/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200406055(PDF, 246K) |
11/13/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200406054(PDF, 238K) |
11/13/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200406053(PDF, 328K) |
11/13/2003 |
| Request relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200406052(PDF, 239K) |
11/12/2003 |
| Request of a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200406051(PDF, 192K) |
11/12/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 402(c)(3)(B) of the Internal Revenue Code. |
| 200406050(PDF, 246K) |
11/12/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200406049(PDF, 245K) |
11/10/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200406048(PDF, 262K) |
11/13/2003 |
| Request a series of private letter rulings under § 408(d)(3) of the Internal Revenue Code. |
| 200406047(PDF, 224K) |
11/14/2003 |
| Whether waivers of the 10 percent excise tax due under § 4971(f)(l) of the Code have been granted with respect to the liquidity shortfalls for the Plan for the second, third, and fourth quarters of the plan year ending December 31, 2000, and the first and second quarters of the plan year ending December 31, 2001. Also whether the waiver of the 100 percent excise tax due under § 4971(f)(2) of the Code has been granted with respect to the liquidity shortfall for the second quarter of the plan year ending December 31, 2000. |
| 200406046(PDF, 79K) |
2/6/2004 |
Issues: (1) Whether investors can claim a theft or other loss on their investment in X’s Equipment? Alternatively, is a bad debt deduction available?
(2) When are the investors entitled to claim a deduction? |
| 200406045(PDF, 86K) |
2/6/2004 |
| Requesting a ruling concerning the application of § 2702 of the Internal Revenue Code. |
| 200406044(PDF, 176K) |
2/6/2004 |
| Requesting rulings under §§ 2041 and 2601 of the Internal Revenue Code. |
| 200406043(PDF, 169K) |
2/6/2004 |
| Requesting rulings under §§ 2036, 2038, 2041, and 2601 of the Internal Revenue Code. |
| 200406042(PDF, 168K) |
2/6/2004 |
| Requesting rulings under §§ 2036, 2038, 2041, and 2601 of the Internal Revenue Code. |
| 200406041(PDF, 206K) |
2/6/2004 |
| Requesting rulings under §§ 2036, 2038, 2041, and 2601 of the Internal Revenue Code. |
| 200406040(PDF, 182K) |
2/6/2004 |
| Requesting rulings under §§ 2041 and 2601 of the Internal Revenue Code. |
| 200406039(PDF, 67K) |
2/6/2004 |
| Request an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2032 of the Internal Revenue Code to make the alternate valuation election provided for in § 2032, with respect to Decedent’s estate. |
| 200406038(PDF, 75K) |
2/6/2004 |
| Requested ruling that the proposed disclaimer will be a qualified disclaimer under § 2518 of the Code, and that the property disclaimed will be treated as passing directly from Decedent’s estate to Decedent’s heirs at law as a result of the disclaimer. |
| 200406037(PDF, 96K) |
2/6/2004 |
| Request for a schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund with respect to the Plant. |
| 200406036(PDF, 90K) |
2/6/2004 |
| Request for a schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund with respect to the Plant. |
| 200406035(PDF, 90K) |
2/6/2004 |
| Requested ruling, filed on behalf of the taxpayer pursuant to the mandatory provisions of § 1.468A-3(i) of the Income Tax regulations, requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200406034(PDF, 95K) |
2/6/2004 |
| Requested ruling, filed on behalf of the taxpayer pursuant to the mandatory provisions of § 1.468A-3(i) of the Income Tax regulations, requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200406033(PDF, 122K) |
2/6/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of generation-skipping transfer exemption to a trust. |
| 200406032(PDF, 33K) |
2/6/2004 |
| Requesting a ruling that Corp A be permitted to change to the tax book value method of asset valuation for purposes of apportioning interest expense for its taxable year beginning on January 1, 2003, and for all subsequent taxable years. |
| 200406031(PDF, 52K) |
2/6/2004 |
| Requesting a ruling under § 301 and 305 of the Internal Revenue Code. |
| 200406030(PDF, 29K) |
2/6/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200406029(PDF, 34K) |
2/6/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200406028(PDF, 40K) |
2/6/2004 |
| Request for an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to file Form 8328 for the Authority to make a carry forward election under § 146(f) of the Internal Revenue Code with respect to $a in unused private activity bond volume cap from 2002. |
| 200406027(PDF, 60K) |
2/6/2004 |
| Request for rulings on certain federal income tax consequences of a partially completed and proposed transaction. |
| 200406026(PDF, 41K) |
2/6/2004 |
| Requesting a ruling under § 162(m) of the Internal Revenue Code. Specifically, a ruling was requested on the application of § 1.162-27(f)(1) of the Income Tax Regulations to certain restricted stock units issued by Company. |
| 200406025(PDF, 60K) |
2/6/2004 |
| Requesting the consent of the Commissioner of the Internal Revenue Service for Taxpayer to make a retroactive qualified electing fund election under § 1295 of the Internal Revenue Code and corresponding Treasury Regulation §1.1295-3(f). |
| 200406024(PDF, 44K) |
2/6/2004 |
| Requesting a ruling that the income of the Association will be excludable from gross income under § 115 of the Internal Revenue Code and that the Association is not required to file annual federal information returns. |
| 200406023(PDF, 34K) |
2/6/2004 |
| Ruling request in which taxpayer A has asked for an extension of time to file Form 1128, Application To Adopt, Change, or Retain a Tax Year, requesting permission to change its taxable year, from a taxable year ending September 30 to a taxable year ending December 31, effective Date 1. |
| 200406022(PDF, 33K) |
2/6/2004 |
| Requested an extension of time, under the provisions of § 301.9100-1 of the Income Tax Regulations, to make an election under §168(h)(6)(F)(ii) of the Internal Revenue Code. |
| 200406021(PDF, 64K) |
2/6/2004 |
| Requesting a ruling for Taxpayer under § 216 of the Internal Revenue Code. |
| 200406020(PDF, 75K) |
2/6/2004 |
| Request, submitted on behalf of Taxpayer and its members (Member A, Member B, and Member C), for rulings under § 29 of the Internal Revenue Code. |
| 200406019(PDF, 75K) |
2/6/2004 |
| Request, submitted on behalf of Taxpayer and its members (Member A, Member B, and Member C), for rulings under § 29 of the Internal Revenue Code. |
| 200406018(PDF, 75K) |
2/6/2004 |
| Request, submitted on behalf of Taxpayer and its members (Member A, Member B, and Member C), for rulings under § 29 of the Internal Revenue Code. |
| 200406017(PDF, 75K) |
2/6/2004 |
| Request, submitted on behalf of Taxpayer and its members (Member A, Member B, and Member C), for rulings under § 29 of the Internal Revenue Code. |
| 200406016(PDF, 54K) |
2/6/2004 |
| Requesting inadvertent termination relief under §1362(f) of the Internal Revenue Code. |
| 200406015(PDF, 56K) |
2/6/2004 |
| Issue: Whether Taxpayer’s component parts described in this memorandum are precluded by Temporary Treasury Regulation § 1.927(a)-1T(d)(2)(iii) from qualifying as export property. |
| 200406014(PDF, 71K) |
2/6/2004 |
| Requesting rulings under § 368 and 355 of the Internal Revenue Code. |
| 200406013(PDF, 40K) |
2/6/2004 |
| 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 Company A and its subsidiaries. |
| 200406012(PDF, 34K) |
2/6/2004 |
| Requesting a ruling under § 877(c) of the Internal Revenue Code 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. |
| 200406011(PDF, 67K) |
2/6/2004 |
| Request for rulings on the federal income tax consequences of a proposed transaction. |
| 200406010(PDF, 67K) |
2/6/2004 |
| Request for rulings on the federal income tax consequences of a proposed transaction. |
| 200406009(PDF, 65K) |
2/6/2004 |
| Request for rulings on the federal income tax consequences of a proposed transaction. |
| 200406008(PDF, 63K) |
2/6/2004 |
| Request for rulings on the federal income tax consequences of a proposed transaction. |
| 200406007(PDF, 56K) |
2/6/2004 |
| Requesting a ruling under the United States-Federal Republic of Germany income tax convention, signed on August 29, 1989, with respect to distributions from the Plan to certain nonresident alien participants who reside in Germany. |
| 200406006(PDF, 54K) |
2/6/2004 |
| Requests rulings on certain federal income tax consequences of a proposed transaction. |
| 200406005(PDF, 51K) |
2/6/2004 |
| Requests a ruling granting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 851(b)(1) of the IRC to be treated as a regulated investment company beginning with its initial taxable year ended Date 1. The Fund also requests a ruling granting an extension of time to make an election under § 855(a) to treat dividends distributed after the close of the taxable year ended Date 1 as having been made during that taxable year. |
| 200406004(PDF, 75K) |
2/6/2004 |
| Requesting a ruling on the gift and estate tax consequences of the establishment of the proposed qualified terminable interest property trust. |
| 200406003(PDF, 53K) |
2/6/2004 |
| Issuer’s request for a ruling that the Corporation meets the criteria of Revenue Ruling 57-128 and therefore is an instrumentality of a political subdivision of State for purposes of § 141 of the Internal Revenue Code. |
| 200406002(PDF, 79K) |
2/6/2004 |
| Ruling request concerning whether the transfer of interconnection facilities to Subsidiary A is a non-shareholder contribution to capital excludable from Subsidiary A’s income under § 118(a) of the Internal Revenue Code. |
| 200406001(PDF, 40K) |
2/6/2004 |
| 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. |
| 200405017(PDF, 364K) |
11/3/2003 |
| Requesting a waiver of the 60-day rollover period with respect to a proposed rollover of a distribution from an IRA annuity by you as the surviving spouse. |
| 200405016(PDF, 329K) |
11/5/2003 |
| Requested certain rulings with respect to its establishment and operation of a wholly-owned, for-profit, taxable subsidiary. |
| 200405015(PDF, 368K) |
11/3/2003 |
| Request a ruling under § 414(d) of the Internal Revenue Code. |
| 200405014(PDF, 227K) |
11/4/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200405013(PDF, 222K) |
11/5/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 408(d)(3) of the Internal Revenue Code. |
| 200405012(PDF, 206K) |
11/5/2003 |
| Request a waiver of the 60-day rollover requirement contained in § 402(c) of the Internal Revenue Code. |
| 200405011(PDF, 80K) |
1/30/2004 |
| Requesting rulings on behalf of Distributing regarding certain Federal income tax consequences of a proposed transaction. |
| 200405010(PDF, 37K) |
1/30/2004 |
| Requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200405009(PDF, 115K) |
1/30/2004 |
| Requesting rulings under Internal Revenue Code §§ 355, 368, 721, and related provisions, with respect to a series of proposed transactions. |
| 200405008(PDF, 34K) |
1/30/2004 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending April 30, to a taxable year ending February 28, effective February 28, Year. |
| 200405007(PDF, 51K) |
1/30/2004 |
| Requested a ruling that in determining Taxpayer’s gross income under § 856(c) of the IRC, Taxpayer will not take into account its allocable share of certain amounts attributable to LLC 3, to the extent that such amounts are attributable to ground rents received by LLC 3 from LLC 2 and do not exceed Taxpayer’s allocable share of deductions attributable to the ground rents paid by LLC 2. |
| 200405006(PDF, 66K) |
1/30/2004 |
| Requesting rulings under §§ 355 and 368 of the Internal Revenue Code with respect to a proposed transaction. |
| 200405005(PDF, 156K) |
1/30/2004 |
Issues: (1) Whether the Payment made by Taxpayer to the State Treasury is deductible under §162 of the Internal Revenue Code as an ordinary and necessary business expense.
(2) If the Payment is not deductible, whether Taxpayer is entitled to relief under § 7805(b) from retroactive revocation of TAM 200126008 (TAM-104871-00, March 6, 2001). |
| 200405004(PDF, 32K) |
1/30/2004 |
| Requesting a ruling on the federal income tax consequences of the termination of a trust. |
| 200405003(PDF, 32K) |
1/30/2004 |
| Requesting a ruling on the federal income tax consequences of the termination of a trust. |
| 200405002(PDF, 70K) |
1/30/2004 |
| Requesting a ruling on the federal income tax consequences of the termination of a trust. |
| 200405001(PDF, 70K) |
1/30/2004 |
| Requesting a ruling on the federal income tax consequences of the termination of a trust. |
