| 200439050(PDF, 46K) |
6/30/2004 |
| Requesting waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200439049(PDF, 44K) |
7/1/2004 |
| Requesting waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200439048(PDF, 37K) |
7/2/2004 |
| Request for a letter ruling concerning the federal income tax treatment of certain contributions under section 414(h)(2) of the Internal Revenue Code. |
| 200439047(PDF, 40K) |
6/29/2004 |
| Requesting waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200439046(PDF, 39K) |
7/2/2004 |
| Requesting waiver of the 60-day rollover requirement contained in section 408(d)(3)(I) of the Internal Revenue Code. |
| 200439045(PDF, 21K) |
6/30/2004 |
| Denied request for a ruling that approves the adoption of a plan amendment that would reduce the future service credit for all active employees and eliminate a 15% post-retirement benefit improvement to all retirees. |
| 200439044(PDF, 41K) |
7/9/2004 |
| Requesting waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200439043(PDF, 51K) |
6/28/2004 |
| Request for rulings under sections 501(c)(3) and 513 of the Internal Revenue Code. |
| 200439042(PDF, 60K) |
5/21/2004 |
| Issue: Whether Taxpayer may deduct Payments A, B, and C, made by Taxpayer in Year 1 to settle certain lawsuits, as ordinary and necessary business expenses under § 162 of the Internal Revenue Code. |
| 200439041(PDF, 51K) |
6/16/2004 |
| Issue: If a bank holds rights to service mortgage loans (mortgages) that are owned by others, may the bank include the mortgages in its loans outstanding for purposes of determining the balance of its reserve for bad debts under § 585 of the Internal Revenue Code? |
| 200439040(PDF, 23K) |
6/2/2004 |
| 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. |
| 200439039(PDF, 17K) |
5/28/2004 |
| Requesting relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200439038(PDF, 30K) |
5/27/2004 |
| Requesting rulings regarding qualification for tax credits under section 45 of the internal Revenue Code. |
| 200439037(PDF, 17K) |
5/28/2004 |
| Requesting relief under §1362(b)(5) of the Internal Revenue Code. |
| 200439036(PDF, 55K) |
6/2/2004 |
| Requesting an extension of time under ' 301.9100-3 of the Procedure and Administration Regulations to sever a trust into an exempt and nonexempt trust for purposes of the Generation-Skipping Transfer (GST) tax and to make a reverse qualified terminable interest property (QTIP) election under ' 2652(a)(3) of the Internal Revenue Code with respect to the exempt trust. |
| 200439035(PDF, 18K) |
5/12/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200439034(PDF, 31K) |
5/13/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200439033(PDF, 35K) |
5/28/2004 |
| Requesting rulings that the (i) income of X is excludable from gross income under section 115 of the Internal Revenue Code, (ii) as a consequence of a ruling on the foregoing, X can disregard its status as an organization described in section 501(c), and (iii) X is obligated to file Form 1120 under section 6012. |
| 200439032(PDF, 26K) |
6/1/2004 |
| Taxpayer requests an extension of time under Treas. Reg. § 301.9100-3 to file certain statements described in § 1.1503-2A and § 1.1503-2 of the regulations. |
| 200439031(PDF, 44K) |
5/25/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g)(1) of the Internal Revenue Code to make allocations of Taxpayer’s generation-skipping transfer (GST) tax exemption. |
| 200439030(PDF, 21K) |
5/18/2004 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as a corporation for federal tax purposes under section 301.7701-3(c). |
| 200439029(PDF, 65K) |
6/3/2004 |
| Request for a ruling regarding the generationskipping transfer tax consequences of the proposed severance and modification of Trust A. |
| 200439028(PDF, 34K) |
5/7/2004 |
| Requesting a ruling under § 1361 of the Internal Revenue Code. |
| 200439027(PDF, 31K) |
5/7/2004 |
| Requesting a ruling under § 1361 of the Internal Revenue Code. |
| 200439026(PDF, 97K) |
5/27/2004 |
| Requesting rulings under § 29 and §702 of the Internal Revenue Code |
| 200439025(PDF, 20K) |
5/28/2004 |
| Requesting relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200439024(PDF, 20K) |
5/25/2004 |
| Requesting a time extension under section 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. |
| 200439023(PDF, 24K) |
5/21/2004 |
| Requesting that the IRS grant 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. |
| 200439022(PDF, 24K) |
5/21/2004 |
| Requesting that the IRS grant 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. |
| 200439021(PDF, 24K) |
5/21/2004 |
| Requesting that the IRS grant 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. |
| 200439020(PDF, 24K) |
5/21/2004 |
| Requesting that the IRS grant 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. |
| 200439019(PDF, 24K) |
5/21/2004 |
| Requesting that the IRS grant 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. |
| 200439018(PDF, 17K) |
5/28/2004 |
| Requested relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200439017(PDF, 54K) |
5/28/2004 |
| Requested certain rulings regarding the proper federal income tax treatment under various provisions of the Internal Revenue Code of 1986 attendant the receipt of certain settlement proceeds received from a company and other, related entities, in connection with the settlement of certain claims for damages resulting from an earthquake. |
| 200439016(PDF, 34K) |
5/27/2004 |
| Requesting a ruling under sections 1014 and 72 of the Internal Revenue Code |
| 200439015(PDF, 21K) |
5/25/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200439014(PDF, 38K) |
6/1/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200439013(PDF, 19K) |
5/28/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200439012(PDF, 18K) |
5/28/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200439011(PDF, 38K) |
5/21/2004 |
| 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 your generation-skipping transfer (GST) tax exemption. |
| 200439010(PDF, 21K) |
6/1/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200439009(PDF, 38K) |
5/24/2004 |
| Requesting rulings under § 355 of the Internal Revenue Code with respect to a proposed transaction. |
| 200439008(PDF, 19K) |
5/27/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200439007(PDF, 25K) |
5/28/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200439006(PDF, 29K) |
5/13/2004 |
| Requesting a ruling that X’s rental income from Property is not passive investment income within the meaning of §§ 1362(d)(3)(C)(i) and 1375 of the Internal Revenue Code. |
| 200439005(PDF, 25K) |
5/27/2004 |
| Request for an extension of time under Treas. Reg. § 301.9100-1 and § 301.9100-3 to submit a ruling request pursuant to section 877(c)(1) of the Internal Revenue Code (the “Code”) and section IV of Notice 97-19, 1997-1 C.B. 394, as modified by Notice 98-34, 1998-2 C.B. 29. |
| 200439004(PDF, 29K) |
5/10/2004 |
| Requesting for 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 carryback period for the consolidated net operating loss ("CNOL") of the consolidated group of which Taxpayer is the common parent. |
| 200439003(PDF, 36K) |
5/21/2004 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200439002(PDF, 44K) |
4/2/2004 |
| Requesting an extension of time under § 2642(g) of the Internal Revenue Code and § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer (GST) exemption. |
| 200439001(PDF, 44K) |
4/2/2004 |
| Requesting an extension of time under § 2642(g) of the Internal Revenue Code and §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer (GST) exemption. |
| 200438051(PDF, 41K) |
6/22/2004 |
| Requesting waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200438050(PDF, 48K) |
6/23/2004 |
| Request for relief under sections 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations. |
| 200438049(PDF, 17K) |
6/24/2004 |
| Request for a ruling regarding the taxation of distributions of a certain section plan, specifically that distributions made under a nontransferable annuity contract will be subject to tax when received. |
| 200438048(PDF, 46K) |
6/24/2004 |
| Requesting waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200438047(PDF, 37K) |
6/24/2004 |
| Requesting waiver of the 60-day rollover requirement contained in section 402(c)(3) of the Internal Revenue Code. |
| 200438046(PDF, 36K) |
6/24/2004 |
| Requesting waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200438045(PDF, 68K) |
6/21/2004 |
| Requesting a private letter ruling under section 408(d)(3) of the Internal Revenue Code. |
| 200438044(PDF, 92K) |
6/22/2004 |
| Requesting a series of letter rulings under section § 401(a)(9) of the Internal Revenue Code. |
| 200438043(PDF, 82K) |
6/25/2004 |
| Requesting a ruling to extend the period to dispose of certain excess business holdings as defined in Section 4943 of the Internal Revenue Code. |
| 200438042(PDF, 78K) |
6/25/2004 |
| Requesting a ruling to extend the period to dispose of certain excess business holdings as defined in Section 4943 of the Internal Revenue Code. |
| 200438041(PDF, 50K) |
6/23/2004 |
| Requesting a ruling to confirm that no tax is due upon the termination and distributions of assets. |
| 200438040(PDF, 32K) |
6/24/2004 |
| Requesting a waiver of the minimum funding standard in accordance with section 412(d) of the Internal Revenue Code and section 303 of the Employee Retirement Income Security Act of 1974. |
| 200438039(PDF, 32K) |
6/24/2004 |
| Requesting a waiver of the minimum funding standard in accordance with section 412(d) of the Internal Revenue Code and section 303 of the Employee Retirement Income Security Act of 1974. |
| 200438038(PDF, 49K) |
6/2/2004 |
| Issue: Is a termination fee received by Taxpayer as the result of a failed merger and acquisition ordinary income or a return of capital and includible in income only to the extent that it exceeds the basis in Taxpayer’s property? |
| 200438037(PDF, 25K) |
5/13/2004 |
| Requesting a ruling that loss of lawful permanent resident status (expatriation) did not have, as one of its principal purposes, the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200438036(PDF, 32K) |
5/10/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make a special use valuation election under section 2032A of the Internal Revenue Code. |
| 200438035(PDF, 37K) |
5/12/2004 |
| Request for rulings regarding certain federal income tax consequences of a proposed transaction. Additional information was received in later correspondence. |
| 200438034(PDF, 34K) |
5/11/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200438033(PDF, 30K) |
5/10/2004 |
| Requesting rulings regarding the application of § 216 of the Internal Revenue Code to Corporation. |
| 200438032(PDF, 61K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200438031(PDF, 60K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200438030(PDF, 60K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200438029(PDF, 58K) |
3/18/2004 |
| Requesting certain rulings under § 704(c) of the Internal Revenue Code (“Code”) and the regulations promulgated thereunder. |
| 200438028(PDF, 46K) |
5/12/2004 |
| Requesting rulings on the application of the income, gift, and estate tax to a proposed transaction. |
| 200438027(PDF, 24K) |
5/26/2004 |
| 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), and the annual certification described in § 1.1503-2(g)(2)(vi)(B). |
| 200438026(PDF, 41K) |
5/11/2004 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer (GST) tax consequences of the proposed division of a trust. |
| 200438025(PDF, 29K) |
5/24/2004 |
| Ruling request for an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to file Form 8328, Carryforward Election of Unused Private Activity Bond Volume Cap. |
| 200438024(PDF, 23K) |
5/12/2004 |
| Request filed on behalf Taxpayer regarding the late filing of a Form 8716, Election To Have a Tax Year Other Than a Required Tax Year. Taxpayer has requested that its late-filed Form 8716 be considered timely filed under authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200438023(PDF, 18K) |
5/12/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200438022(PDF, 23K) |
5/25/2004 |
| Request for an extension of time under Treas. Reg. §301.9100-3 to file an election agreement described in §1.1503-2(g)(2)(i) (the 2(g)(2)(i) election agreement) for the tax year ended on Date A with respect to the dual consolidated losses of Entities A through J (inclusive), a 2(g)(2)(i) election agreement for the tax year ended on Date B with respect to the dual consolidated losses of Entities B through M (inclusive), and an annual certification statement described in §1.1503-2(g)(2)(vi)(B) (2(g)(2)(vi)(B) certification) for the tax year ended on Date B with respect to the dual consolidated loss of Entity B incurred in the tax year ended on Date A. |
| 200438021(PDF, 61K) |
5/14/2004 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations. Information was submitted pursuant to § 1.468A-3(h)(2). |
| 200438020(PDF, 51K) |
5/17/2004 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations. |
| 200438019(PDF, 61K) |
5/18/2004 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations. Information was submitted pursuant to § 1.468A-3(h)(2). |
| 200438018(PDF, 51K) |
5/21/2004 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations. |
| 200438017(PDF, 51K) |
5/17/2004 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations. |
| 200438016(PDF, 61K) |
5/11/2004 |
| Request for a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations. Information was submitted pursuant to § 1.468A-3(h)(2). |
| 200438015(PDF, 32K) |
5/5/2004 |
| Request for rulings regarding the federal income tax consequences of certain proposed transactions. |
| 200438014(PDF, 26K) |
5/25/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an alternate valuation election under § 2032 of the Internal Revenue Code. |
| 200438013(PDF, 63K) |
5/6/2004 |
| Request for a revised schedule of ruling amounts (“SRA”) pursuant to § 1.468A-3(i) of the Income Tax Regulations. Information was submitted pursuant to § 1.468A-3(h)(2). |
| 200438012(PDF, 52K) |
5/17/2004 |
| Request concerning the generation-skipping transfer (GST) tax and income tax consequences of the proposed division of Trust. |
| 200438011(PDF, 23K) |
5/17/2004 |
| 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 November 30, to a taxable year ending December 31, effective December 31, 2002. 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. |
| 200438010(PDF, 42K) |
5/14/2004 |
| Requesting a ruling supplementing the prior letter ruling ( PLR 200405009, PLR- 152829-02 ) (the "Prior Ruling"). The Prior Ruling addresses transactions treated for Federal income tax purposes as a transfer by "Distributing" of the "Region C" Assets to "Controlled" in exchange for "Controlled’s" assumption of the "Region C" liabilities and all of "Controlled’s" stock (other than a subscriber share), a distribution by "Distributing" of its "Controlled" Stock to the "Region C" Members in exchange for a portion of the "Region C" Members’ equity in "Distributing" and a transfer by each "Region C" Member of its "Controlled" stock and its remaining equity in "Distributing" to "Partnership" in exchange for an Interest in "Partnership." |
| 200438009(PDF, 18K) |
5/10/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200438008(PDF, 76K) |
4/30/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200438007(PDF, 22K) |
5/13/2004 |
| Request filed on behalf of Taxpayer regarding the late filing of a Form 8716, Election To Have a Tax Year Other Than a Required Tax Year. Taxpayer has requested that its late-filed Form 8716 be considered timely filed under authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200438006(PDF, 18K) |
5/12/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200438005(PDF, 32K) |
5/14/2004 |
| Request for a waiver under section 7702(f)(8) of the Internal Revenue Code for Number V life insurance contracts (the "Contracts") that inadvertently failed to meet the requirements of section 7702. |
| 200438004(PDF, 31K) |
5/18/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code that the termination of Company's S corporation election was inadvertent. |
| 200438003(PDF, 19K) |
5/11/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200438002(PDF, 24K) |
5/4/2004 |
| 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 Internal Revenue Code. |
| 200438001(PDF, 19K) |
5/7/2004 |
| Requesting rulings under § 1361 of the Internal Revenue Code that Trust be allowed to revoke its electing small business trust (ESBT) election and elect to be treated as a qualified subchapter S trust (QSST). |
| 200437040(PDF, 111K) |
6/7/2004 |
| Issues: (1) Did the X, an organization recognized under section 501(c)(3) of the Internal Revenue Code, have a substantial nonexempt purpose during the years ###, and, if so, should X’s exempt status be revoked? (2) Have the net earnings of X inured to the benefit of private individuals in contravention of section 501(c)(3) of the Code and, if so, should X's exempt status be revoked? (3) Did X, a religious organization exempt from federal income tax, intervene in a political campaign in contravention of section 501(c)(3) of the Code when its principal minister made statements in opposition to a candidate for President of the United States and, if so, should its exempt status be revoked? (4) Is X subject to tax under section 4955 of the Code on amounts expended for political activities? (5) If X continues to qualify for exemption, should it be classified as a "church" within the meaning of sections 509(a)(1) and 170(b)(1)(A)(i) of the Code? |
| 200437039(PDF, 30K) |
6/17/2004 |
| Conditional waiver of the minimum funding standard granted in accordance with section 412(d) of the Internal Revenue Code and section 303 of the Employee Retirement Income Security Act of 1974. |
| 200437038(PDF, 48K) |
6/17/2004 |
| Request for ruling as to whether certain proposed methods of calculating distributions from an IRA will constitute a series of substantially equal 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. |
| 200437037(PDF, 57K) |
6/15/2004 |
| Request for a ruling with respect to attempted conversions from traditional IRAs to Roth IRAs for the 1998 tax year. |
| 200437036(PDF, 102K) |
6/17/2004 |
| Request for rulings on the consequences of a reorganization involving 3 corporations. |
| 200437035(PDF, 95K) |
4/30/2004 |
| Issues: (1) Whether for purposes of the Uniform Capitalization Rules under § 263A of the Internal Revenue Code (UNICAP), direct labor is an appropriate base to develop standard costs to allocate storage and handling costs to the taxpayer’s inventory. (2) If direct labor is not an appropriate base to develop standard costs to allocate storage and handling costs to the taxpayer’s inventory, what method may the Commissioner use to allocate the taxpayer’s storage and handling costs? |
| 200437034(PDF, 46K) |
4/30/2004 |
| Issue: Under the facts described below, whether Taxpayer’s method of determining the amount of scrap costs includible in inventory costs is a reasonable allocation method within the meaning of § 1.263A-1(f)(4). |
| 200437033(PDF, 110K) |
5/20/2004 |
| Issues: (1) Whether the preferred stock arrangement can “voluntarily restrict” earnings and profits and, thus restrict the controlled foreign corporation’s distribution of subpart F income under sections 951, 952, 954 and 956 of the Code to the common units while any preferred units remain outstanding in CFC2. (2) Whether the preferred stock arrangement can be defined and recharacterized under the “fast pay” regulations of Treas. Reg. §1.7701(l)-3(b) and further, if so should this financing instrument be treated as debt or equity. |
| 200437032(PDF, 67K) |
5/11/2004 |
| Issue: Does Decedent’s residuary bequest to Beneficiary, an individual who is a member of a religious order and has taken a vow of poverty, qualify for an estate tax charitable deduction under § 2055(a) of the Internal Revenue Code? |
| 200437031(PDF, 48K) |
6/3/2004 |
| Issues: (1) Under the circumstances described below, whether Taxpayer’s construction of prehung doors constitutes the production of tangible personal property within the meaning of § 263A(g)(1) of the Internal Revenue Code and §§ 1.263A-2(a)(1) and 1.263A-2(a)(2) of the Income Tax Regulations, and therefore Taxpayer is a reseller with production activities within the meaning of § 1.263A-3(a)(2). (2) If the answer to Issue (1) is “yes,” whether Taxpayer’s production activities are de minimis within the meaning of § 1.263A-3(a)(2)(iii). (3) If the answer to Issue (1) is “yes” and the answer to Issue (2) is “no,” whether the Commissioner may require Taxpayer to use using any method that in his opinion clearly reflects the taxpayer's taxable income. |
| 200437030(PDF, 57K) |
4/30/2004 |
| Issue: Whether an employer-provided holiday gift coupon with a face value of thirty-five dollars that is redeemable at several local grocery stores is excluded from gross income and wages as a de minimis fringe benefit under Internal Revenue Code (Code) § 132(a)(4). |
| 200437029(PDF, 36K) |
4/20/2004 |
| Request for rulings regarding certain Federal income tax consequences of a partially completed and proposed transaction. |
| 200437028(PDF, 40K) |
5/20/2004 |
| Request for rulings concerning the Federal income tax treatment of certain disability benefits paid to City firefighters and police officers and their survivors. |
| 200437027(PDF, 25K) |
5/6/2004 |
| 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 to be classified as a corporation. |
| 200437026(PDF, 24K) |
4/28/2004 |
| Requesting a ruling that X be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c) to be treated as an association taxable as a corporation for federal tax purposes. |
| 200437025(PDF, 24K) |
4/28/2004 |
| Requesting a ruling that X be granted an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c) to be treated as an association taxable as a corporation for federal tax purposes. |
| 200437024(PDF, 72K) |
4/21/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437023(PDF, 61K) |
5/4/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437022(PDF, 61K) |
5/4/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437021(PDF, 62K) |
4/21/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437020(PDF, 61K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437019(PDF, 61K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437018(PDF, 60K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437017(PDF, 60K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437016(PDF, 60K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437015(PDF, 61K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437014(PDF, 61K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437013(PDF, 60K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200437012(PDF, 58K) |
4/26/2004 |
| Requesting a ruling concerning the income, gift, and generation-skipping transfer (GST) tax consequences of the proposed settlement. |
| 200437011(PDF, 81K) |
4/29/2004 |
| Requesting rulings concerning the generation-skipping transfer tax, estate tax, gift tax, and income tax consequences of the proposed modification of Trust. |
| 200437010(PDF, 29K) |
4/27/2004 |
| Requesting a ruling for an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to file Form 8328, Carryforward Election of Unused Private Activity Bond Volume Cap, to make a carryforward election under § 146(f) of the Internal Revenue Code. |
| 200437009(PDF, 22K) |
5/6/2004 |
| Requesting an extension of time under section 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 to file a late S corporation election under section 1362(b)(5) of the Internal Revenue Code. |
| 200437008(PDF, 21K) |
5/5/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200437007(PDF, 76K) |
4/30/2004 |
| Requesting rulings under § 29 of the Internal Revenue Code. |
| 200437006(PDF, 22K) |
6/7/2004 |
| Requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations for Parent to file a copy of a Form 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. |
| 200437005(PDF, 23K) |
5/11/2004 |
| Request for an extension of time under Treas. Reg. § 301.9100-3 for Taxpayers to each elect the provisions of Revenue Procedure 89-45, 1989-2 C.B. 596, for the Election Year. |
| 200437004(PDF, 35K) |
4/26/2004 |
| Requesting a ruling on the generation-skipping transfer (GST) tax consequences of the modification of "Trust 2." |
| 200437003(PDF, 31K) |
4/26/2004 |
| Requesting a ruling on the generation-skipping transfer (GST) tax consequences of the modification of "Trust." |
| 200437002(PDF, 23K) |
6/14/2004 |
| 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 an association taxable as a corporation for federal tax purposes. |
| 200437001(PDF, 56K) |
8/3/2004 |
| Issues: (1) Whether the Service’s use of a private information source during a criminal investigation violates the Right to Financial Privacy Act (“RFPA”), 12 U.S.C. §§ 3401-3422? (2) If so, whether applicable disclosure and privacy laws prevent the Service from using as an investigative resource during a criminal investigation? |
| 200436023(PDF, 47K) |
6/8/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200436022(PDF, 90K) |
6/9/2004 |
| Request for a ruling regarding the federal income tax consequences of a joint venture arrangement. |
| 200436021(PDF, 37K) |
6/10/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200436020(PDF, 35K) |
6/10/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200436019(PDF, 37K) |
6/4/2004 |
| Request for a ruling that X meets the requirements of Rev. Proc. 95-48, 1995-2 C.B. 418, to qualify as an affiliate of a government unit and therefore not be required to file Form 990, Return of Organization Exempt from the Federal Income Tax. |
| 200436018(PDF, 30K) |
6/8/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200436017(PDF, 76K) |
6/7/2004 |
| Request for a letter ruling under setions 402(a), 402(c)(3), and 408(d) of the Internal Revenue Code ( the Code ) and a letter ruling under section 691 of the Code. |
| 200436016(PDF, 55K) |
6/8/2004 |
| Requesting a ruling concerning the applicability of the provisions of sections 419 and 419A of the Internal Revenue Code to contributions made to a fund in the event that the employer's bargaining unit employees become participants of the fund. |
| 200436015(PDF, 61K) |
6/9/2004 |
| Request for a private letter ruling concerning the deductibility of contributions under section 404 of the Internal Revenue Code. |
| 200436014(PDF, 35K) |
6/9/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200436013(PDF, 55K) |
6/9/2004 |
| Request for a ruling under section 414(e) of the Internal Revenue Code. |
| 200436012(PDF, 56K) |
6/9/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3)(I) of the Internal Revenue Code. |
| 200436011(PDF, 39K) |
4/30/2004 |
| Issue: Can a gross income allocation to X be a significant item of partnership income or gain which has substantial economic effect for purposes of § 1.752-3(a)(3) allowing X to be allocated 100 percent of the excess nonrecourse liabilities? |
| 200436010(PDF, 31K) |
5/4/2004 |
| Requesting a ruling regarding the application of § 216 of the Internal Revenue Code. |
| 200436009(PDF, 71K) |
4/21/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200436008(PDF, 61K) |
5/4/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200436007(PDF, 61K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200436006(PDF, 60K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200436005(PDF, 61K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200436004(PDF, 61K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200436003(PDF, 60K) |
4/9/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200436002(PDF, 32K) |
5/6/2004 |
| Request for a private letter ruling in which the Taxpayer, has requested to revoke an election under § 108(b) (5) of the Internal Revenue Code. |
| 200436001(PDF, 36K) |
4/27/2004 |
| Requesting an extension of time under sections 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make a qualified terminal interest property election (QTIP election) under section 2056(b)(7)(B)(v) of the Internal Revenue Code. |
| 200435022(PDF, 47K) |
5/5/2004 |
| Issues: (1) Whether X is an applicable tax-exempt organization. (2) Whether C is a disqualified person as defined by section 4958(f)(1)(B) of the Internal Revenue Code (Code), with respect to X. (3) Whether the use of X assets by C is an excess benefit transaction as defined by section 4958(c)(1)(A). 2 of 11 (4) What is the taxable period for period for assessment of possible tax liability for excess benefit transactions. (5) Whether C is liable for the excise tax imposed by section 4958(a)(1) of the Code that is equal to 25 percent of the excess benefit. (6) Whether C is liable for the excise tax imposed by section 4958(b) of the Code that is equal to 200 percent of the excess benefit transaction if the transaction is not corrected within the taxable period. |
| 200435021(PDF, 68K) |
5/5/2004 |
| Issues: (1) Whether X is an applicable tax-exempt organization. (2) Whether B is a disqualified person as defined by section 4958(f)(1)(B) of the Internal Revenue Code (Code), with respect to X. (3) Whether the use of X’s assets by B is an excess benefit transaction as defined by section 4958(c)(1)(A). 2 of 16 (4) What is the taxable period for the excess benefit transactions. (5) Whether B is liable for the excise tax imposed by section 4958(a)(1) of the Code that is equal to 25 percent of the excess benefit. (6) Whether B is liable for the excise tax imposed by section 4958(b) of the Code that is equal to 200 percent of the excess benefit transaction if the transaction is not corrected within the taxable period. |
| 200435020(PDF, 66K) |
5/5/2004 |
| Issues: (1) Whether X is an applicable tax-exempt organization. (2) Whether A is a disqualified person as defined by section 4958(f)(1)(A) of the Internal Revenue Code (Code), with respect to X. 2 of 17 (3) Whether the use of X’s assets by A is an excess benefit transaction as defined by section 4958(c)(1)(A). (4) What is the taxable period for the excess benefits transactions. (5) Whether A is liable for the excise tax imposed by section 4958(a)(1) of the Code that is equal to 25 percent of the excess benefit. (6) Whether A is liable for the excise tax imposed by section 4958(b) of the Code that is equal to 200 percent of the excess benefit transaction if the transaction is not corrected within the taxable period. |
| 200435019(PDF, 45K) |
5/5/2004 |
| Issues: (1) Whether X is an applicable tax-exempt organization. (2) Whether D is a disqualified person as defined by section 4958(f)(1)(B) of the Internal Revenue Code (Code), with respect to X. (3) Whether the use of X’s assets by D constitutes an excess benefit transaction as defined by section 4958(c)(1)(A). (4) What is the taxable period for the excess benefit transactions. 2 (5) Whether D is liable for the excise tax imposed by section 4958(a)(1) of the Code that is equal to 25 percent of the excess benefit. (6) Whether D is liable for the excise tax imposed by section 4958(b) of the Code that is equal to 200 percent of the excess benefit transaction if the transaction is not corrected within the taxable period. |
| 200435018(PDF, 42K) |
5/5/2004 |
| Issues: (1) Whether X is an applicable tax-exempt organization. (2) Whether E is a disqualified person as defined by section 4958(f)(1)(B) of the Internal Revenue Code (Code), with respect to X. (3) Whether the use of an X asset by E is an excess benefit transaction as defined by section 4958(c)(1)(A). (4) What is the taxable period for the excess benefit transactions. 2 of 9 (5) Whether E is liable for the excise tax imposed by section 4958(a)(1) of the Code that is equal to 25 percent of the excess benefit. (6) Whether E is liable for the excise tax imposed by section 4958(b) of the Code that is equal to 200 percent of the excess benefit transaction if the transaction is not corrected within the taxable period. |
| 200435017(PDF, 41K) |
5/21/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200435016(PDF, 19K) |
6/1/2004 |
| Request with respect to defined benefit pension plan pursuant to Revenue Procedure 90-49 for the plan year. |
| 200435015(PDF, 45K) |
5/11/2004 |
| Issue: Whether life insurance reserves based upon the net surrender value of insurance contracts should be reduced by the net value of risks reinsured on a yearly renewable term (YRT) basis. |
| 200435014(PDF, 28K) |
4/29/2004 |
| Requesting that the Commissioner, pursuant to § 1.1502-75(b)(3) of the Income Tax Regulations (the “Regulations”), treat Subsidiary 2 as if it had filed a Form 1122 for Tax Year for purposes of § 1.1502-75(h)(2), and thus joined in the making of the consolidated return with Parent and Subsidiary 1. |
| 200435013(PDF, 21K) |
5/5/2004 |
| Request for an extension of time under Treas. Reg. § 301.9100-3 to elect the provisions of Revenue Procedure 89-45, 1989-2 C.B. 596, for the Election Year. |
| 200435012(PDF, 61K) |
5/4/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200435011(PDF, 62K) |
5/4/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200435010(PDF, 62K) |
5/4/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200435009(PDF, 62K) |
4/21/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200435008(PDF, 62K) |
4/21/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a settlement agreement modifying the terms of trusts that are exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200435007(PDF, 37K) |
5/6/2004 |
| Request for a ruling that interest income earned on certain funds while under the dominion and control of the U.S. Marshals Service is not income to Taxpayer under § 61 of the Internal Revenue Code. |
| 200435006(PDF, 46K) |
4/26/2004 |
| Request concerning the income and gift tax consequences of Taxpayer’s disclaimers. |
| 200435005(PDF, 35K) |
4/30/2004 |
| Requesting rulings as to the federal income tax consequences of a proposed transaction. |
| 200435004(PDF, 21K) |
5/6/2004 |
| Requesting a time extension under section 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. |
| 200435003(PDF, 36K) |
5/6/2004 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200435002(PDF, 39K) |
5/5/2004 |
| Request for rulings on the federal income tax consequences of a partially consummated transaction. |
| 200435001(PDF, 40K) |
7/28/2004 |
| Oregon Child Care Credit. |
