| 200434029(PDF, 61K) |
3/26/2004 |
| Issue: If a bank creates a wholly-owned subsidiary to hold, service, invest, and reinvest the bank’s investment assets, should all of the assets (including tax-exempt obligations) and interest expense of the subsidiary be treated as those of the bank for purposes of applying § 265(b) and § 291(a)(3) and (e)(1)(B) of the Internal Revenue Code? |
| 200434028(PDF, 62K) |
5/25/2004 |
| Request for rulings concerning the federal income tax consequences of transfer of obligations and the assets that secure them to a for-profit entity pursuant to section 150(d)(3) of the Internal Revenue Code. |
| 200434027(PDF, 32K) |
5/24/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200434026(PDF, 45K) |
5/26/2004 |
| Request for a ruling that set-aside funds be recognized as satisfying the suitability test of section 4942(g)(2)(B)(i) of the Internal Revenue Code section 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations. |
| 200434025(PDF, 36K) |
5/25/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200434024(PDF, 18K) |
5/25/2004 |
| Request for a waiver of the minimum funding standard for a defined benefit pension plan. |
| 200434023(PDF, 26K) |
5/26/2004 |
| Conditional waiver granted in accordance with section 412(d) of the Internal Revenue Code and section 303 of the Employee Retirement Income Security Act of 1974. |
| 200434022(PDF, 49K) |
3/12/2004 |
| Issue: If a bank creates a wholly-owned subsidiary to hold, service, invest, and reinvest the bank’s investment assets, should all of the assets (including tax-exempt obligations) and interest expense of the subsidiary be treated as those of the bank for purposes of applying § 265(b) and § 291(a)(3) and (e)(1)(B) of the Internal Revenue Code? |
| 200434021(PDF, 57K) |
3/12/2004 |
| Issue: If a bank creates a wholly-owned subsidiary to hold, service, invest, and reinvest the bank’s investment assets, should all of the assets (including tax-exempt obligations) and interest expense of the subsidiary be treated as those of the bank for purposes of applying § 265(b) and § 291(a)(3) and (e)(1)(B) of the Internal Revenue Code? |
| 200434020(PDF, 28K) |
4/30/2004 |
| Issue: For purposes of the excise tax imposed by § 4051(a)(1) of the Internal Revenue Code on the first retail sale of truck semitrailer bodies and chassis, may Taxpayer exclude from its taxable sale price of the X vehicle described below that portion of the sale price attributable to the aluminum extrusion assembly? |
| 200434019(PDF, 41K) |
4/19/2004 |
| Issue: May Taxpayer treat as a contribution to capital under § 118(a) of the Internal Revenue Code the Continued Dumping and Subsidy Offset (Offset) it received from the federal government under the Continued Dumping and Subsidy Offset Act of 2000 (CDSOA)? |
| 200434018(PDF, 21K) |
4/28/2004 |
| Requesting a ruling under § 301.9100-3(a) of the Procedure and Administration Regulations that Taxpayer be granted an extension of time to make an election to be treated as a partnership for federal income tax purposes. |
| 200434017(PDF, 23K) |
4/27/2004 |
| Requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations for Parent to file copies of three Forms 3115, Application for Change in Accounting Method, with the Internal Revenue Service (IRS) national office. This request was made in accordance with § 301.9100-3. |
| 200434016(PDF, 18K) |
4/7/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200434015(PDF, 78K) |
4/23/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200434014(PDF, 77K) |
4/23/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200434013(PDF, 26K) |
4/28/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election to be classified as a corporation for federal tax purposes, and for X to be treated as an S corporation under § 1362(b)(5) of the Internal Revenue Code. |
| 200434012(PDF, 31K) |
4/23/2004 |
| Requesting rulings under § 671 of the Internal Revenue Code. |
| 200434011(PDF, 24K) |
4/20/2004 |
| Requesting a ruling that loss of permanent resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitles A or B of the Code. |
| 200434010(PDF, 80K) |
2/13/2004 |
| Requesting rulings as to the federal income tax consequences of a proposed transaction. |
| 200434009(PDF, 22K) |
4/29/2004 |
| Request for an extension of time under Treas. Reg. §301.9100-3 to file the election agreement described in §1.1503-2(g)(2)(i) (the 2(g)(2)(i) agreement) for the tax year ended on Date A with respect to Entity A’s and Entity B’s dual consolidated losses and the annual certification statement described in §1.1503-2(g)(2)(vi)(B) (2(g)(2)(vi)(B) certification) for tax years ended on Date B and Date C with respect to Entity A’s and Entity B’s dual consolidated losses incurred in the tax year ended on Date A. |
| 200434008(PDF, 39K) |
4/19/2004 |
| Requesting various rulings concerning the income tax consequences of the Plan and Trust. |
| 200434007(PDF, 51K) |
5/3/2004 |
| Request for a ruling concerning the consequences under former section 167(l), former section 46(f), and section 168(i)(9) of the Internal Revenue Code of the deemed acquisition of the assets of a regulated natural gas pipeline and natural gas storage business.for a ruling concerning the consequences under former section 167(l), former section 46(f), and section 168(i)(9) of the Internal Revenue Code of the deemed acquisition of the assets of a regulated natural gas pipeline and natural gas storage business. |
| 200434006(PDF, 24K) |
4/29/2004 |
| Requesting relief under section 1362(f) of the Internal Revenue Code. |
| 200434005(PDF, 27K) |
4/26/2004 |
| Requesting under § 301.9100-3 of the Procedure and Administration Regulations an extension of time to elect application of section 468A of the Internal Revenue Code with respect to Taxpayer’s interest in Plant and the related Nuclear Decommissioning Reserve Fund. |
| 200434004(PDF, 30K) |
4/20/2004 |
| Requesting a ruling regarding the application of ' 216(b) of the Internal Revenue Code to Corporation. |
| 200434003(PDF, 79K) |
4/23/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200434002(PDF, 26K) |
4/27/2004 |
| Requesting relief for inadvertent termination of subchapter S election under § 1362(f) of the Internal Revenue Code. |
| 200434001(PDF, 36K) |
7/2/2004 |
| IRC section 6673(a)(1) and offers-in compromise. |
| 200433031(PDF, 151K) |
5/20/2004 |
| Ruling letter concering transfer of all assets from trust to college in 12-month termination of private foundation status pursuant to section 507(b)(1)(A) of the internal Revenue Code and section 1.507-2(a)(5) of the Income Tax Regulations. |
| 200433030(PDF, 126K) |
5/19/2004 |
| Request for a waiver of the 60-day rollover requirement in section 402(c) of the Internal Revenue Code. |
| 200433029(PDF, 119K) |
5/18/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200433028(PDF, 82K) |
5/18/2004 |
| Request for ruling concerning sections 4941 and 4944 of the Internal Revenue Code in regard to a specific stock compromising about 90 percent of X's assets. |
| 200433027(PDF, 109K) |
5/21/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200433026(PDF, 186K) |
5/18/2004 |
| Request for a series of letter rulings under section 408(d)(3) of the Internal Revenue Code. |
| 200433025(PDF, 198K) |
5/17/2004 |
| Request for an extension of time pursuant to section 301.9100-1 of the Procedure and Administration Regulations to file the notice of election described in section 3 of the Revenue Procedure 93-40, 1993-2 C.B. 535 to be treated as operating qualified seperate lines of business under section 414(r)(20 f the Internal Revenue Code of 1986 and sections 1.414(r)-I(b) and 1.414(r)-4 of the Treasury Regulations. |
| 200433024(PDF, 117K) |
5/17/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200433023(PDF, 118K) |
5/18/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200433022(PDF, 125K) |
5/21/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200433021(PDF, 184K) |
5/21/2004 |
| Request for a ruling that plan X is a church plan within the meaning of section 414(e) of the Internal Revenue Code. |
| 200433020(PDF, 182K) |
5/21/2004 |
| Request for a waiver of the 60-day rollover requirement in section 402(c)(3) of the Internal Revenue Code. |
| 200433019(PDF, 290K) |
5/21/2004 |
| Request for letter rulings under section 401(a)(9) of the Internal Revenue Code. |
| 200433018(PDF, 131K) |
5/21/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200433017(PDF, 34K) |
4/22/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200433016(PDF, 30K) |
4/13/2004 |
| Requesting a reasonable extension of time pursuant to sections 301.9100-1 and section 301.9100-3 of the Procedure and Administration Regulations to make an election. Specifically, Trust requests a reasonable extension of time to make an election under section 860D of the Internal Revenue Code and section 1.860-1(d) of the Income Tax Regulations to be treated as a Real Estate Mortgage Investment Conduit ( REMIC ). |
| 200433015(PDF, 21K) |
4/21/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200433014(PDF, 59K) |
4/30/2004 |
| Requesting rulings under §§ 1001, 2501, and 2601 of the Internal Revenue Code. |
| 200433013(PDF, 24K) |
4/20/2004 |
| Requesting a ruling that loss of permanent resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitles A or B of the Code. |
| 200433012(PDF, 25K) |
4/29/2004 |
| Requesting a ruling that certain trusts are qualified subchapter S trusts under section 1361(d)(3)of the Internal Revenue Code. |
| 200433011(PDF, 70K) |
4/13/2004 |
| Requesting rulings regarding the federal income and generation-skipping transfer (GST) tax consequences of a proposed severance of certain trusts. |
| 200433010(PDF, 49K) |
4/27/2004 |
| Request for a private letter ruling that digital or electronic receipts, as described below, without any accompanying paper receipts, constitute adequate records for purposes of the substantiation requirements of section 274(d) of the Internal Revenue Code. |
| 200433009(PDF, 38K) |
4/21/2004 |
| Requesting rulings regarding the proposed division of two grandfathered generation-skipping transfer (GST) trusts. Specifically, rulings are requested under §§ 61, 1001, and 2601 of the Internal Revenue Code. |
| 200433008(PDF, 34K) |
4/22/2004 |
| Requesting a ruling on behalf of Taxpayer and Subsidiary granting Taxpayer and Subsidiary an extension of time under sections 301.9100-1 and 301.9100-3 of the Procedure and Administration regulations to file an election for Subsidiary to be treated as a taxable REIT subsidiary (TRS) of Taxpayer under section 856(l) of the Internal Revenue Code. |
| 200433007(PDF, 32K) |
4/21/2004 |
| Request to supplement the letter ruling PLR-146773-03. |
| 200433006(PDF, 21K) |
4/26/2004 |
| This is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the taxpayer requesting permission to change its accounting period, for federal income tax purposes. The taxpayer has requested that the Form 1128 be considered timely filed under the authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200433005(PDF, 37K) |
4/23/2004 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration regulations to file an election to treat Corporation B as a taxable REIT subsidiary of Corporation A under § 856(l) of the Internal Revenue Code. |
| 200433004(PDF, 30K) |
4/26/2004 |
| Requesting under § 301.9100-3 of the Procedure and Administration Regulations an extension of time to elect application of section 468A of the Internal Revenue Code with respect to Taxpayer’s interest in Plant and the related Nuclear Decommissioning Reserve Fund (Fund). |
| 200433003(PDF, 35K) |
4/21/2004 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration regulations to file an election to treat Corporation B as a taxable REIT subsidiary of Trust B under § 856(l) of the Internal Revenue Code. |
| 200433002(PDF, 25K) |
4/26/2004 |
| Requesting a ruling on behalf of the Fund concerning whether certain disability benefits received under the Statute are excludable from gross income under section 104(a)(1) of the Internal Revenue Code. |
| 200433001(PDF, 19K) |
4/21/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code |
| 200432031(PDF, 120K) |
5/10/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200432030(PDF, 169K) |
5/13/2004 |
| Request for relief under section 301.9100-3 of the Procedure and Administration Regulations. |
| 200432029(PDF, 373K) |
5/12/2004 |
| Request for letter rulings under section 401(a)(9) of the Internal Revenue Code. |
| 200432028(PDF, 372K) |
5/12/2004 |
| Request for letter rulings under section 401(a)(9) of the Internal Revenue Code. |
| 200432027(PDF, 371K) |
5/12/2004 |
| Request for letter rulings under section 401(a)(9) of the Internal Revenue Code. |
| 200432026(PDF, 160K) |
5/12/2004 |
| Request for rulings concerning the applicability of sections 514, 4941 and 4945 of the Internal Revenue Code to loan proceeds from real property. |
| 200432025(PDF, 131K) |
8/5/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 402(c) of the Internal Revenue Code. |
| 200432024(PDF, 148K) |
5/11/2004 |
| Request for a ruling as to whether a proposed method of calculating distributions from an individual retirement account ( IRA ) will constitute a series of substantially equal periodic payments and will not be subject to the 10 percent additional tax imposed on premature distributions under section 72(t) of the Internal Revenue Code. |
| 200432023(PDF, 151K) |
5/11/2004 |
| Request for a ruling as to whether a proposed method of calculating distributions from an individual retirement account ( IRA ) will constitute a series of substantially equal periodic payments and will not be subject to the 10 percent additional tax imposed on premature distributions under section 72(t) of the Internal Revenue Code. |
| 200432022(PDF, 121K) |
5/12/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200432021(PDF, 160K) |
5/11/2004 |
| Request for a ruling as to whether a proposed method of calculating distributions from an individual retirement account ( IRA ) will constitute a series of substantially equal periodic payments and will not be subject to the 10 percent additional tax imposed on premature distributions under section 72(t) of the Internal Revenue Code. |
| 200432020(PDF, 158K) |
5/12/2004 |
| Request for relief under section 301.9100-3 of the Procedure and Administration Regulations. |
| 200432019(PDF, 109K) |
5/14/2004 |
| Request for a waiver of the minimum funding standard. |
| 200432018(PDF, 41K) |
5/12/2004 |
| Request with respect to defined benefit pension plan pursuant to Revenue Procedure 90-49. |
| 200432017(PDF, 99K) |
1/23/2004 |
| Request for rulings on certain federal income tax consequences of proposed transactions. |
| 200432016(PDF, 22K) |
3/10/2004 |
| Issue: Whether the amount of gift tax paid by Decedent, with respect to gifts made on Date 1, Year 1, was properly excluded from Decedent’s gross estate under section 2035(b) of the Internal Revenue Code? |
| 200432015(PDF, 60K) |
3/10/2004 |
| Issues: (1) Is any portion of the proceeds payable on Policy, an insurance policy on Decedent’s life, includible in Decedent’s gross estate under sections 2035(a) and 2042? (2) If any portion of the Policy proceeds is includible in Decedent’s gross estate, then to what extent, if any, is Decedent’s estate entitled to an estate tax marital deduction under section 2056(a) with respect to the proceeds? |
| 200432014(PDF, 52K) |
4/6/2004 |
| Issues: For purposes of applying the corporate equity reduction transaction (CERT) rules of sections 172(b)(1)(E) and (h): (1) Should the interest expense incurred by Target on post-CERT third-party debt be included in the determination of the allocable interest deduction for the loss limitation years? (2) Should the interest expense incurred by Target on pre-CERT third-party debt be included in the P group's 3-year interest expense average for purposes of calculating the allocable interest deduction limitation under section 172(h)(2)(C)? |
| 200432013(PDF, 26K) |
4/20/2004 |
| Requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations for Parent to file copies of two Forms 3115, Application for Change in Accounting Method, with the Internal Revenue Service (IRS) national office. This request was made in accordance with § 301.9100-3. |
| 200432012(PDF, 43K) |
4/22/2004 |
| Request for a ruling submitted by an authorized representative of a Retiree Committee. |
| 200432011(PDF, 45K) |
4/16/2004 |
| Request of Taxpayer for a revised schedule of ruling amounts for pursuant to section 1.468A-3(i)(2) of the Income Tax Regulations. |
| 200432010(PDF, 24K) |
4/16/2003 |
| 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. |
| 200432009(PDF, 70K) |
4/13/2004 |
| Requesting rulings regarding the federal income and generation-skipping transfer (GST) tax consequences of a proposed severance of certain trusts. |
| 200432008(PDF, 70K) |
4/13/2004 |
| Requesting rulings regarding the federal income and generation-skipping transfer (GST) tax consequences of a proposed severance of certain trusts. |
| 200432007(PDF, 70K) |
4/13/2004 |
| Requesting rulings regarding the federal income and generation-skipping transfer (GST) tax consequences of a proposed severance of certain trusts. |
| 200432006(PDF, 70K) |
4/13/2004 |
| Requesting rulings regarding the federal income and generation-skipping transfer (GST) tax consequences of a proposed severance of certain trusts. |
| 200432005(PDF, 70K) |
4/13/2004 |
| Requesting rulings regarding the federal income and generation-skipping transfer (GST) tax consequences of a proposed severance of certain trusts. |
| 200432004(PDF, 110K) |
10/1/2003 |
| Requesting rulings as to certain federal income tax consequences of a series of proposed transactions. |
| 200432003(PDF, 38K) |
4/21/2004 |
| Requesting rulings regarding the proposed division of two grandfathered generation-skipping transfer (GST) trusts. Specifically, rulings are requested under §§ 61, 1001, and 2601 of the Internal Revenue Code. |
| 200432002(PDF, 30K) |
4/22/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent is requesting an extension of time to file an election under § 1.1502-32(b)(4) to waive loss carryovers from a separate return limitation year to the extent the loss carryovers exceed $d (the “Election”). |
| 200432001(PDF, 23K) |
4/26/2004 |
| 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 treated as an entity disregarded as separate from its owner under section 301.7701-3(c). |
| 200431023(PDF, 131K) |
7/30/2004 |
| Legal analysis of whether credit counseling organizations can qualify for exemption as charitable or educational organizations described in section 501(c)(3). |
| 200431022(PDF, 137K) |
5/7/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200431021(PDF, 113K) |
5/7/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200431020(PDF, 73K) |
5/7/2004 |
| Request for certain rulings relating to the tax consequences of a proposed transaction. |
| 200431019(PDF, 125K) |
5/7/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200431018(PDF, 242K) |
5/6/2004 |
| Tax consequences of a proposed transaction. |
| 200431017(PDF, 290K) |
5/4/2004 |
| Request for relief under section 301.9100-3 of the Procedure and Administration Regulations. |
| 200431016(PDF, 173K) |
5/3/2004 |
| Request for relief under section 301.9100-3 of the Procedure and Administration Regulations. |
| 200431015(PDF, 12K) |
6/1/2004 |
| Doubt as to Liability Offers-in-Compromise and Unenrolled Return Preparers. |
| 200431014(PDF, 53K) |
4/29/2004 |
| Whether an individual who holds an Illinois CPA certificate, but is not a licensed public accountant, may practice before the IRS. |
| 200431013(PDF, 23K) |
4/29/2004 |
| Whether an individual who holds an Illinois CPA certificate, but is not a licensed public accountant, may practice before the IRS. |
| 200431012(PDF, 96K) |
6/29/2004 |
| Issues: (1) Are the benefits that a property owner receives under the programs described above for elevating the foundation of a structure on that property excluded from gross income under the Stafford Act, the general welfare exclusion, § 102 (as a gift), or § 139 (as a qualified disaster relief payment), or as a government-created property right? (2) Do the benefits that the owner of a building receives under the programs described above for elevating the foundation of that building under the HMGP qualify for deferral of recognition of gain as an involuntary conversion under § 1033? (3) What amount must a property owner who receives a benefit under the programs described above for elevating the foundation of a structure on that property include in income? (4) Are state and local governments required to file information returns for payments made on behalf of homeowners under the FMA, the PDM, and the HMGP? |
| 200431011(PDF, 22K) |
4/21/2004 |
| Requesting a ruling under § 301.9100-3(a) of the Procedure and Administration Regulations that X be granted an extension of time to make an election under § 754 of the Internal Revenue Code. |
| 200431010(PDF, 22K) |
4/16/2004 |
| Requesting an extension of time to make an election under § 42(i)(2)(B) of the Internal Revenue Code pursuant to § 301- 9100-1 of the Procedure and Administration Regulations. |
| 200431009(PDF, 73K) |
4/14/2004 |
| Requesting rulings under § 29 and § 708 of the Internal Revenue Code. |
| 200431008(PDF, 19K) |
4/21/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200431007(PDF, 23K) |
4/15/2004 |
| This is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending June 30, to a taxable year ending December 31, effective December 31, 2001. The taxpayer has requested that the Form 1128 be considered timely filed under the authority contained in section 301.9100-3 of the Procedure and Administration Regulations. |
| 200431006(PDF, 47K) |
4/16/2004 |
| Requesting rulings regarding the generation-skipping transfer (GST) tax treatment of the proposed division and modification of two trusts. |
| 200431005(PDF, 38K) |
4/13/2004 |
| Requesting an extension of time pursuant to § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations to allocate Taxpayer’s generation-skipping transfer (GST) tax exemption to a transfer made to a charitable remainder trust. |
| 200431004(PDF, 19K) |
4/8/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200431003(PDF, 64K) |
4/16/2004 |
| Requesting rulings under § 29 and § 708 of the Internal Revenue Code. |
| 200431002(PDF, 27K) |
4/15/2004 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Parent and its subsidiaries to make an election 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. |
| 200431001(PDF, 25K) |
3/26/2004 |
| Request for a ruling that bonds to be issued to current refund the Advance Refunding Bonds will not be private activity bonds under § 141(b) of the Internal Revenue Code. |
| 200430044(PDF, 58K) |
1/16/2004 |
| Issues : (1) Whether a taxpayer that is changing its method of accounting for costs subject to § 263A of the Internal Revenue Code with respect to non-inventory property may revalue such property using the 3-year average method described in § 1.263A- 7(c)(2)(v) of the Income Tax Regulations. (2) Whether a taxpayer that is changing its method of accounting for costs subject to § 263A with respect to non-inventory property may use a 3-year average, similar to the 3-year average method described in § 1.263A-7(c)(2)(v), as a reasonable estimate and procedure when using the facts and circumstances method provided by § 1.263A-7(c)(2)(iii). (3) Whether a taxpayer that is changing its method of accounting for costs subject to § 263A with respect to non-inventory property may use the exception provided in § 1.263A-7(c)(2)(iii)(B). |
| 200430043(PDF, 105K) |
4/26/2004 |
| Request for approval of a proposed set-aside grant to be made under the suitability test of section 4942(g)(2)(B)(i) of the Internal Revenue Code and section 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations. |
| 200430042(PDF, 110K) |
4/28/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200430041(PDF, 133K) |
4/28/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c) of the Internal Revenue Code. |
| 200430040(PDF, 108K) |
4/30/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200430039(PDF, 166K) |
4/30/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200430038(PDF, 110K) |
4/30/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200430037(PDF, 142K) |
4/30/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200430036(PDF, 106K) |
4/30/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200430035(PDF, 134K) |
4/30/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200430034(PDF, 364K) |
4/28/2004 |
| Request for ruling with respect to the creation of the Excess Benefit Plan and its effect on the Pension Trust. |
| 200430033(PDF, 117K) |
4/30/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200430032(PDF, 123K) |
4/29/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200430031(PDF, 132K) |
4/29/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3) of the Internal Revenue Code. |
| 200430030(PDF, 38K) |
3/24/2004 |
| Issue: Whether the election made by Decedent’s estate to deduct the value of Decedent’s qualified family-owned business interests under § 2057 is valid. |
| 200430029(PDF, 161K) |
3/25/2004 |
| Issue: (1) In determining the foreign sales corporation (“FSC”) commission payable by USCorp to USCorp-FSC, whether the taxpayer may compute the overall profit percentage (“OPP”) under Temp. Treas. Reg. § 1.925(b)-1T(c)(2) of the marginal costing rules for a product by using the OPP for the product or product line grouping in which the product is included if, with respect to other products in the same product line, the taxpayer uses an OPP determined at a different, overlapping level of the product line hierarchy. (2) In determining the extraterritorial income (“ETI”) exclusion under section 114, whether USCorp may compute the OPP under the section 941(a)(4) marginal costing rules for a product by using the OPP for the product or product line grouping in which the product is included if, with respect to other products in the same product line, USCorp uses an OPP determined at a different, overlapping level of the product line hierarchy. |
| 200430028(PDF, 59K) |
4/8/2004 |
| The ruling concerns the issue of whether the Taxpayer will be “operating on a cooperative basis” within the meaning of subchapter T of the Internal Revenue Code. |
| 200430027(PDF, 26K) |
4/2/2004 |
| 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. |
| 200430026(PDF, 20K) |
4/14/2004 |
| Requesting a ruling concerning the federal tax consequences of a transaction. |
| 200430025(PDF, 53K) |
4/2/2004 |
| Request for rulings on the federal income tax consequences of a proposed transaction. |
| 200430024(PDF, 34K) |
4/9/2004 |
| Recent submissions, reaffirming representations made in connection with a prior request for a private letter ruling and representing facts not previously represented. X asks to rule that the additional facts now represented will not adversely affect prior rulings concerning X. |
| 200430023(PDF, 31K) |
4/9/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200430022(PDF, 23K) |
4/2/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200430021(PDF, 27K) |
4/9/2004 |
| Requesting an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested to file an election under §1.1502-20T(i)(4) of the Income Tax Regulations to apply the provisions described in §1.1502-20T(i)(2)(i) to determine the basis reduction on the deconsolidation occurring upon the contribution of stock during the taxable year. |
| 200430020(PDF, 19K) |
4/2/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200430019(PDF, 24K) |
4/7/2004 |
| Requesting a ruling under section 280G of the Internal Revenue Code. Specifically, a ruling is requested that certain amounts were included in the base amount for purposes of determining whether the "Corporation" is subject to any deduction limit under section 280G of the Code and whether the participants are subject to an excise tax under section 4999. |
| 200430018(PDF, 69K) |
4/7/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200430017(PDF, 69K) |
4/7/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200430016(PDF, 22K) |
4/8/2004 |
| Request for an extension of time under Treas. Reg. § 301.9100-3 to file the election agreement described in § 1.1503-2(g)(2)(i) with respect to the dual consolidated losses incurred by X and with respect to the dual consolidated losses incurred by Y in the tax years. |
| 200430015(PDF, 24K) |
4/13/2004 |
| Request for an extension of time under Treas. Reg. § 301.9100-3 to file a separate election agreement described in § 1.1503-2(g)(2)(i) and to file the annual certification described in § 1.1503-2(g)(2)(vi)(B). |
| 200430014(PDF, 36K) |
4/13/2004 |
| Requesting an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer (GST) tax exemption. |
| 200430013(PDF, 23K) |
4/9/2004 |
| Requesting a ruling concerning the application of section 457 of the Internal Revenue Code ( Code ) to the nonqualified deferred compensation plan that the Federal Credit Union, CU, intends to implement for an executive in the near future. CU is represented to be a federal credit union that is a tax-exempt entity described in section 501(c)(1) of the Code. |
| 200430012(PDF, 61K) |
4/13/2004 |
| Request for a ruling on the estate tax consequences of a proposed reformation of Reinstated Trust. |
| 200430011(PDF, 34K) |
4/5/2004 |
| Requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make a qualified terminable interest (QTIP) election under §2056(b)(7) of the Internal Revenue Code. |
| 200430010(PDF, 34K) |
3/22/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a proposed judicial modification of Trust. |
| 200430009(PDF, 34K) |
3/22/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a proposed judicial modification of Trust. |
| 200430008(PDF, 30K) |
3/16/2004 |
| Requesting a ruling that income is excluded from gross income under section 115 of the Internal Revenue Code. |
| 200430007(PDF, 23K) |
4/14/2004 |
| Request filed on behalf of the taxpayer regarding the late filing of its Form 8716, Election To Have a Tax Year Other Than a Required Tax Year. The taxpayer requests that the Form 8716 be considered timely filed under authority contained in section 301.9100-3 of the Procedure and Administration Regulations. |
| 200430006(PDF, 27K) |
4/14/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file a copy of a Form 3115, Application for Change in Accounting Method, with the Internal Revenue Service (IRS) national office. |
| 200430005(PDF, 29K) |
3/30/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as a corporation for federal tax purposes under § 301.7701-3(c) as well as relief to file a late Form 2553, S Corporation Election, under § 1362(b)(5) of the Internal Revenue Code. |
| 200430004(PDF, 24K) |
4/8/2004 |
| Taxpayer requests an extension of time under Treas. Reg. § 301.9100-3 to file the following: (1) the election and agreement described in §1.1503-2(g)(2)(i) with respect to the dual consolidated losses incurred by Entity A in the tax year ended on Date 1; (2) a separate election and agreement described in §1.1503-2(g)(2)(i) with respect to the dual consolidated losses incurred by Entity A and Entity B in the tax year ended on Date 2; and (3) the annual certification described in § 1.1503-2(g)(2)(vi) for the tax year ended on Date 2 with respect to the dual consolidated losses incurred by Entity A in the tax year ended on Date 1. |
| 200430003(PDF, 28K) |
4/12/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent is requesting an extension to file a “§ 1.337(d)-2T(c) statement” under § 1.337(d)-2T(c)(3) that was supposed to be filed with its consolidated Federal income tax return. |
| 200430002(PDF, 31K) |
4/7/2004 |
| Request for rulings under § 2056 of the Internal Revenue Code. |
| 200430001(PDF, 30K) |
4/14/2004 |
| Requesting an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election. |
