| 200449045(PDF, 148K) |
5/7/2004 |
| Requesting exemption from Federal income tax under section 501(c)(7) of the Internal Revenue Code. |
| 200449044(PDF, 90K) |
8/9/2004 |
| Revocation letter concerning an exempt status under section 501(c) (3) of the Internal Revenue Code. |
| 200449043(PDF, 318K) |
9/8/2004 |
| Requesting a ruling letter concerning the application of the pre-termination restrictions of section 1.401 (a)(4)-5(b) of the Income Tax Regulations. |
| 200449042(PDF, 533K) |
9/8/2004 |
| Requesting letter rulings under section 401 (a)(9) of the Internal Revenue Code. |
| 200449041(PDF, 532K) |
9/8/2004 |
| Requesting letter rulings under section 401 (a)(9) of the Internal Revenue Code. |
| 200449040(PDF, 443K) |
9/8/2004 |
| Requesting letter rulings under section 401 (a)(9) and 408(d)(3) of the Internal Revenue Code. |
| 200449039(PDF, 231K) |
9/8/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200449038(PDF, 232K) |
9/10/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200449037(PDF, 219K) |
9/10/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200449036(PDF, 33K) |
9/8/2004 |
| Requesting letter rulings concerning section 501(c)(9) of the Internal Revenue Code. |
| 200449035(PDF, 39K) |
9/9/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200449034(PDF, 22K) |
9/10/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(2). |
| 200449033(PDF, 26K) |
9/7/2004 |
| Requesting rulings under sections 513, 514, and 501(m)(5) of the Internal Revenue Code. |
| 200449032(PDF, 49K) |
7/29/2004 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations and section 2642(g) of the Internal Revenue Code to make an allocation of the generation-skipping transfer (GST) exemption to transfers to certain trusts. |
| 200449031(PDF, 38K) |
7/29/2004 |
| Requesting a ruling concerning the deductibility of interest expense under section 2053 of the Internal Revenue Code. |
| 200449030(PDF, 23K) |
8/4/2004 |
| Requesting an extension of time, pursuant to 2 § 301.9100-3 of the Procedure and Administration Regulations, to file Form 8832, Entity Classification Election, to elect to treat an association taxable as a corporation for federal tax purposes. |
| 200449029(PDF, 88K) |
8/11/2004 |
| Requesting rulings regarding the estate and generation-skipping transfer (GST) tax consequences of a proposed modification to a trust that is exempt from the application of the GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200449028(PDF, 24K) |
8/4/2004 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an alternate valuation election under § 2032 of the Internal Revenue Code with respect to the decedent’s estate. |
| 200449027(PDF, 25K) |
8/11/2004 |
| Requesting extensions of time under §§ 301.9100-1 through 301.9100- 3 of the Procedure and Administration Regulations to file elections to be treated as disregarded entities for federal tax purposes. |
| 200449026(PDF, 25K) |
8/11/2004 |
| Requesting extensions of time under §§ 301.9100-1 through 301.9100- 3 of the Procedure and Administration Regulations to file elections to be treated as disregarded entities for federal tax purposes. |
| 200449025(PDF, 31K) |
8/12/2004 |
| Requesting an extension of time pursuant to Treas. Reg. §301.9100-1 to file the elective agreements required under Treas. Reg. §1.1503-2(g)(2)(i); the annual certification statements required by Treas. Reg. §1.1503-2(g)(2)(vi)(B); and the agreements described in Treas. Reg. §1.1503-2(g)(2)(iv)(B)(2)(iii). |
| 200449024(PDF, 47K) |
8/11/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to sever a trust into an exempt trust and non-exempt trust under § 26.2654-1(b)(1) of the Generation-Skipping Transfer (GST) Tax Regulations 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. |
| 200449023(PDF, 23K) |
8/17/2004 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200449022(PDF, 45K) |
8/17/2004 |
| 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 generation-skipping transfer (GST) tax exemption to transfers made to a trust. |
| 200449021(PDF, 17K) |
8/4/2004 |
| Requesting relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200449020(PDF, 46K) |
7/22/2004 |
| Request for rulings concerning the generation-skipping transfer (GST) tax and income tax consequences of the proposed merger of two trusts. |
| 200449019(PDF, 46K) |
7/22/2004 |
| Request for rulings concerning the generation-skipping transfer (GST) tax and income tax consequences of the proposed merger of two trusts. |
| 200449018(PDF, 26K) |
8/16/2004 |
| Requesting a ruling that the income of Company is excluded from gross income under § 115(1) of the Internal Revenue Code. |
| 200449017(PDF, 28K) |
8/12/2004 |
| Requesting rulings concerning the taxability of the Annuity Contract held by a trustee on behalf of a beneficiary under § 72(u)(1) of the Internal Revenue Code and the applicability of § 72(e)(4)(C) to a distribution, in kind, of a portion of the Annuity Contract to the beneficiary. |
| 200449016(PDF, 30K) |
8/13/2004 |
| Requesting a ruling concerning the taxability of the Annuity Contract held by a trustee on behalf of the trust under § 72(u)(1) of the Internal Revenue Code. |
| 200449015(PDF, 26K) |
8/13/2004 |
| Requesting a ruling concerning the taxability of the Annuity Contract held by a trustee on behalf of the trust under § 72(u)(1) of the Internal Revenue Code. |
| 200449014(PDF, 30K) |
8/12/2004 |
| Requesting rulings concerning the taxability of the Annuity Contract held by a trustee on behalf of a beneficiary under § 72(u)(1) of the Internal Revenue Code and the applicability of § 72(e)(4)(C) to a distribution, in kind, of an annuity contract (or annuity contracts) to a separate trust for the beneficiary. |
| 200449013(PDF, 26K) |
8/12/2004 |
| Requesting a ruling concerning the taxability of the Annuity Contracts held by a trustee on behalf of a beneficiary under § 72(u)(1) of the Internal Revenue Code. |
| 200449012(PDF, 25K) |
8/12/2004 |
| Requesting a ruling under section 162(m) of the Internal Revenue Code. Specifically, a ruling on the treatment of restricted stock units issued and that may continue to be issued following an initial public offering. |
| 200449011(PDF, 26K) |
8/13/2004 |
| Requesting a ruling concerning the taxability of the Annuity Contracts held by a trustee on behalf of a beneficiary under § 72(u)(1) of the Internal Revenue Code. |
| 200449010(PDF, 23K) |
8/17/2004 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200449009(PDF, 57K) |
8/5/2004 |
| Requesting supplemental rulings to the initial ruling letter dated February 13, 2004, PLR-147741-03 (the “Prior Letter Ruling”). The Prior Letter Ruling addresses the federal income tax consequences of a proposed transaction under section 355 of the Internal Revenue Code consisting of Domestication and Distributions. |
| 200449008(PDF, 52K) |
8/19/2004 |
| Requesting a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations. A schedule of ruling amounts was previously issued. Ownership of a plant was transferred to a new owner in the context of a tax-free reorganization under § 351 of the Internal Revenue Code. The new owner has requested and received a schedule of ruling amounts for a period beginning with the year following the transfer of the plant. The Service ruled on the tax consequences of that transfer on the taxpayer, the new owner, and the fund. The Service also granted relief under section 301.9100-3 with respect to the filing of this request for private letter ruling. Information was submitted pursuant to § 1.468A-3(h)(2). |
| 200449007(PDF, 29K) |
8/2/2004 |
| Requesting rulings under §§ 301.7701-3(c) and 301-9100-3 of the Procedure and Administration Regulations (regarding a late entity classification election) and § 1362(b)(5) of the Internal Revenue Code (regarding a late S corporation election). |
| 200449006(PDF, 94K) |
8/11/2004 |
| Requesting rulings on the generation-skipping transfer (GST), gift, and estate tax consequences resulting from the proposed division of several trusts. |
| 200449005(PDF, 24K) |
8/9/2004 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations to file an election to treat X as an association for federal tax purposes and relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200449004(PDF, 20K) |
8/3/2004 |
| Requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations, to be granted an extension of time to file an election under section 301.7701-3(c). |
| 200449003(PDF, 116K) |
7/27/2004 |
| Requesting a private letter ruling concerning the tax consequences of the sale of a nuclear power plant and associated assets and liabilities, including nuclear decommissioning liability. Specifically, rulings regarding the tax consequences under section 468A of the Internal Revenue Code of a seller's and buyer's nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the nuclear power plant and associated assets. |
| 200449002(PDF, 32K) |
8/17/2004 |
| 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 generation-skipping transfer (GST) tax exemptions to transfers made to an irrevocable trust. |
| 200449001(PDF, 44K) |
9/7/2004 |
| Issues: (1) Whether Taxpayer is entitled to deduct the excess of the fair market value of the cash, notes and new common stock it transferred to certain creditors, pursuant to its Plan of Reorganization, over the amount of each creditor’s claim. (2) Whether section 1032 of the Code otherwise bars a deduction of the excess amount. |
| 200448055(PDF, 92K) |
8/31/2004 |
| Requesting a conditional waiver of the minimum funding standard. |
| 200448054(PDF, 176K) |
9/1/2004 |
| Requesting a conditional waiver of the minimum funding standard. |
| 200448053(PDF, 87K) |
9/1/2004 |
| Requesting a conditional waiver of the minimum funding standard. |
| 200448052(PDF, 158K) |
9/2/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200448051(PDF, 65K) |
8/31/2004 |
| Requesting a ruling under section 4943 of the Internal Revenue Code. |
| 200448050(PDF, 65K) |
8/31/2004 |
| Requesting a ruling under section 4943 of the Internal Revenue Code. |
| 200448049(PDF, 65K) |
8/31/2004 |
| Requesting a ruling under section 4943 of the Internal Revenue Code. |
| 200448048(PDF, 84K) |
8/31/2004 |
| Requesting the following rulings: (1) Whether your participation in LLC-A, including the acquisition and retention of a membership interest in LLC-A will not adversely affect your exempt status under section 501(c)(3) of the Code? (2) Whether your participation in LLC-A will not adversely affect your continued treatment as an organization described in sections 509(a)(1)/170(b)(1)(A)(iii) of the Code? (3) Whether the income received from your distributive share of LLC-A’s profits will be income from a related trade or business and will not be subject to tax under section 511 of the Code? (4) Whether your participation in LLC-B, including the acquisition and retention of a membership interest in LLC-B will not adversely your exemption as an organization described in section 501(c)(3) of the Code? (5) Whether your participation in LLC-B will not adversely affected your continued treatment as an organization described in sections 509(a)(1)/170(b)(1)(A)(iii) of the Code? (6) Whether the income received from your distributive share of LLC-B’s profits will be income from a related trade or business and will not be subject to the tax on unrelated business taxable income under section 511 of the Code? |
| 200448047(PDF, 59K) |
8/30/2004 |
| Issues: (1) How are the issue prices of notes CN #1, CN #2, and SN determined? a. Does § 1.1275-2(c) of the Income Tax Regulations apply to aggregate CN #2 and SN? b. If CN #2 and SN are aggregated, what is the issue price of the aggregated note? c. If CN #2 and SN are aggregated, what is the issue price of CN #1? (2) If CN #2 and SN are aggregated, what is the adjusted basis of SN on the date that Seller sells SN to Note Buyer? |
| 200448046(PDF, 84K) |
8/30/2004 |
| Issue: Whether the Taxpayer may use the very conservative reserve method required only by Connecticut that it used to compute its statutory reserves in the annual statements filed in all states to compute federal tax reserves for Minimum Guaranteed Death Benefits associated with deferred variable annuity contracts issued prior to the effective date of Actuarial Guideline XXXIV. |
| 200448045(PDF, 20K) |
7/8/2004 |
| Requesting advisory opinion on collection of taxes with regards to Internal Revenue Code §§ 6201(a)(3), 6213(b), 6501(c)(1) and 7206(1). |
| 200448044(PDF, 24K) |
7/26/2004 |
| Requesting relief under section 1362(f) of the Internal Revenue Code for inadvertent termination of an S election. |
| 200448043(PDF, 42K) |
8/4/2004 |
| Requesting extensions of time under §§ 2652(a)(3) and 2654 of the Internal Revenue Code and § 301.9100-1 of the Procedure and Administration Regulations to sever Trust into Trust A and Trust B and to make a reverse qualified terminable interest property (QTIP) election with respect to Trust B. |
| 200448042(PDF, 43K) |
8/9/2004 |
| Requesting rulings regarding the generation-skipping transfer (GST) tax and income tax consequences of a judicial modification to an irrevocable trust. |
| 200448041(PDF, 23K) |
7/26/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200448040(PDF, 64K) |
7/28/2004 |
| Requesting certain rulings under the Internal Revenue Code concerning § 3.4 and the death of grantors. |
| 200448039(PDF, 20K) |
7/22/2004 |
| Requesting permission to revoke an election under § 41(c)(4) of the Internal Revenue Code. |
| 200448038(PDF, 36K) |
8/6/2004 |
| Requesting a ruling to disregard a marital deduction taken on Decedent’s federal estate tax return with respect to the actuarial value of Spouse’s interest in property passing under Decedent’s will to Decedent’s children and a credit shelter trust in which Spouse had a life interest. |
| 200448037(PDF, 28K) |
8/4/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200448036(PDF, 36K) |
8/6/2004 |
| Requesting a ruling that a Class 1 or Class 2 Exchange Market Maker that satisfies the Section 1256 Dealer Qualification quotation requirements described below is a dealer in securities futures contracts (SFCs) within the meaning of § 1256(g)(9)(B) of the Internal Revenue Code. |
| 200448035(PDF, 29K) |
8/11/2004 |
| Requesting an extension of time under Treas. Reg. §301.9100-3 to file the election statements described in Treas. Reg. §1.1503-2(g)(2)(i); the annual certification statements described in Treas. Reg. §1.1503-2(g)(2)(vi)(B); and the agreement described in Treas. Reg. §1.1503-2(g)(2)(iv)(B)(2)(iii). |
| 200448034(PDF, 33K) |
8/6/2004 |
| Issues: (1) Exchange is a a "qualified board or exchange" within the meaning of § 1256(g)(7) of the Internal Revenue Code. (2) A Class 1, Class 2, or Class 3 Exchange Market Maker that functions as described below is a dealer in securities futures contracts (SFCs) within the meaning of § 1256(g)(9)(B). |
| 200448033(PDF, 19K) |
8/2/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200448032(PDF, 26K) |
6/23/2004 |
| Requesting an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as an association taxable as a corporation for federal tax purposes under §301.7701-3(c). |
| 200448031(PDF, 20K) |
8/16/2004 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to submit a ruling request under I.R.C. § 877 as provided by Section IV of Notice 97-19, 1997-1 C.B. 394, as modified by Notice 98-34, 1998-2 C.B. 29. |
| 200448030(PDF, 17K) |
7/21/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200448029(PDF, 33K) |
7/28/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an election under section 2057(b)(1)(B) of the Internal Revenue Code. |
| 200448028(PDF, 21K) |
8/5/2004 |
| Requesting permission for Corporation to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200448027(PDF, 37K) |
7/28/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make a qualified domestic trust (QDOT) election under § 2056A(d) of the Internal Revenue Code. |
| 200448026(PDF, 21K) |
7/30/2004 |
| Requesting a ruling that the surrender of a green card (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200448025(PDF, 21K) |
7/30/2004 |
| Requesting a ruling that the surrender of a green card (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200448024(PDF, 40K) |
7/27/2004 |
| Requesting certain rulings under § 704 of the Internal Revenue Code. |
| 200448023(PDF, 46K) |
7/22/2004 |
| Request concerning the generation-skipping transfer (GST) tax and income tax consequences of the proposed merger of two trusts. |
| 200448022(PDF, 46K) |
7/22/2004 |
| Request concerning the generation-skipping transfer (GST) tax and income tax consequences of the proposed merger of two trusts. |
| 200448021(PDF, 46K) |
7/22/2004 |
| Request concerning the generation-skipping transfer (GST) tax and income tax consequences of the proposed merger of two trusts. |
| 200448020(PDF, 46K) |
7/22/2004 |
| Request concerning the generation-skipping transfer (GST) tax and income tax consequences of the proposed merger of two trusts. |
| 200448019(PDF, 46K) |
7/22/2004 |
| Request concerning the generation-skipping transfer (GST) tax and income tax consequences of the proposed merger of two trusts. |
| 200448018(PDF, 46K) |
7/22/2004 |
| Request concerning the generation-skipping transfer (GST) tax and income tax consequences of the proposed merger of two trusts. |
| 200448017(PDF, 28K) |
7/30/2004 |
| Request for a ruling that the acquisition of certainelectric power combustion turbine generator sets with the proceeds of the Bonds will not constitute acquisition of “nongovernmental output property” under § 141(d) of the Internal Revenue Code. |
| 200448016(PDF, 20K) |
7/28/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200448015(PDF, 99K) |
7/29/2004 |
| Requesting rulings under section 168 (h)(1)(B) of the Internal Revenue Code regarding a multifaceted transaction that includes the rehabilitation of a historic building. |
| 200448014(PDF, 22K) |
7/26/2004 |
| Requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations, to be granted an extension of time to elect to be treated as an association taxable as a corporation under section 301.7701-3(c). |
| 200448013(PDF, 65K) |
7/26/2004 |
| Requesting a ruling regarding the application of § 367(e)(2) of the Internal Revenue Code with respect to a proposed transaction. |
| 200448012(PDF, 23K) |
7/28/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200448011(PDF, 25K) |
8/3/2004 |
| 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. |
| 200448010(PDF, 33K) |
8/4/2004 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200448009(PDF, 26K) |
7/28/2004 |
| Requesting that the Commissioner make a determination, under § 1.1502-75(b)(2) of the Income Tax Regulations. |
| 200448008(PDF, 32K) |
7/19/2004 |
| requesting a ruling under § 118 of the Internal Revenue Code. |
| 200448007(PDF, 19K) |
8/4/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200448006(PDF, 52K) |
7/19/2004 |
| Requesting a ruling concerning the valuation, for Generation-Skipping Transfer (GST) Tax purposes, of certain interests over which an election for alternate valuation under § 2032A of the Internal Revenue Code was made. |
| 200448005(PDF, 52K) |
8/18/2004 |
| Requesting a revised schedule of ruling amounts pursuant to § 1.468A-3(i) of the Income Tax Regulations. |
| 200448004(PDF, 23K) |
7/28/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200448003(PDF, 25K) |
7/29/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200448002(PDF, 116K) |
7/28/2004 |
| Requesting a private letter ruling concerning the tax consequences of the sale of a nuclear power plant and associated assets and liabilities, including nuclear decommissioning liability, between Seller and Buyer. Specifically, rulings regarding the tax consequences under section 468A of the Internal Revenue Code to Seller's nuclear decommissioning funds and Buyer's nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the nuclear power plant and associated assets. |
| 200448001(PDF, 46K) |
7/21/2004 |
| Requesting a ruling concerning the income and generation-skipping transfer tax (GST) consequences of a proposed modification of a trust. |
| 200447051(PDF, 150K) |
8/26/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3) of the Internal Revenue Code. |
| 200447050(PDF, 330K) |
5/18/2004 |
| Requesting recognition of exemption from Federal income tax under the provision of section 501(c)(3) of the Internal Revenue Code of 1986 and its applicable Income Tax Regulations. |
| 200447049(PDF, 475K) |
6/15/2004 |
| Requesting recognition of exemption from Federal income tax under the provision of section 501(c)(3) of the Internal Revenue Code of 1986 and its applicable Income Tax Regulations. |
| 200447048(PDF, 558K) |
5/18/2004 |
| Requesting recognition of exemption from Federal income tax under the provision of section 501(c)(3) of the Internal Revenue Code of 1986 and its applicable Income Tax Regulations. |
| 200447047(PDF, 566K) |
6/17/2004 |
| Requesting recognition of exemption from Federal income tax under the provision of section 501(c)(3) of the Internal Revenue Code of 1986 and its applicable Income Tax Regulations. |
| 200447046(PDF, 1206K) |
6/7/2004 |
| Requesting recognition of exemption from Federal income tax under section 501(a) of the Internal Revenue Code and as an organization described in section 501(c)(3). |
| 200447045(PDF, 171K) |
8/23/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200447044(PDF, 36K) |
8/24/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200447043(PDF, 133K) |
8/26/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200447042(PDF, 158K) |
8/26/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200447041(PDF, 176K) |
8/27/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3) of the Internal Revenue Code. |
| 200447040(PDF, 594K) |
8/24/2004 |
| Request for letter rulings under sections 2056, 2518,402 and 457 of the Internal Revenue Code. |
| 200447039(PDF, 291K) |
8/27/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200447038(PDF, 15K) |
8/24/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200447037(PDF, 162K) |
8/24/2004 |
| Issue: (1) When one consolidated group (the “historic Acquiror group”) acquires a second consolidated group (the “historic Target group”) that qualifies as a “gain corporation” for purposes of § 384 of the Internal Revenue Code of 1986, as amended (the “Code”), 1 whether one determines that there is a loss that must be allocated between the preacquisition and post-acquisition periods of the acquisition year for purposes of § 384 by calculating separately the items of income, gain, loss and deduction for each of the historic Acquiror group and the historic Target group (the “separate group approach”) or by calculating such items on a combined group basis (the “combined group approach”). (2) Regardless of whether the separate group approach or the combined group approach is used to determine that there is a loss that must be allocated between the preacquisition and post-acquisition periods of the year of acquisition for purposes of § 384, whether such loss may be allocated between such periods using the “closing-ofthe- books” method. (3) If a loss must be allocated between the preacquisition and post-acquisition periods of the year of acquisition for purposes of § 384, whether it is necessary to determine the order of absorption of preacquisition and post-acquisition losses within the year of acquisition. (4) Whether the amount of the historic Target group’s recognized built-in gain (within the meaning of § 384) (“RBIG”) may be offset by some portion of the historic Target group’s operating expenses for the year in which the RBIG was recognized. |
| 200447036(PDF, 38K) |
10/5/2004 |
| Issue: Whether section 6503(h) of the Internal Revenue Code (Code) suspends the period of limitations on collection for dischargeable tax liabilities during the period that a discharge in a Chapter 7 bankruptcy case is granted to the time the discharge is revoked. |
| 200447035(PDF, 52K) |
8/16/2004 |
| Issues: (1) How does section 692 apply to multiple periods of service in a combat zone? (2) How does section 7508(a) affect the statute of limitations on filing a claim for refund under section 6511 when the taxpayer served in and out of combat zones and then died while serving in a combat zone? |
| 200447034(PDF, 21K) |
7/7/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200447033(PDF, 26K) |
7/6/2004 |
| Requesting a ruling concerning the effect of a judicial reformation of a trust on the qualification of the trust as a charitable remainder unitrust (CRUT) under § 664. |
| 200447032(PDF, 32K) |
7/28/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a proposed partition of a trust. |
| 200447031(PDF, 127K) |
11/19/2003 |
| Requesting rulings regarding certain federal income tax consequences of a series of proposed transactions. |
| 200447030(PDF, 48K) |
7/19/2004 |
| Requesting a ruling regarding the automatic allocation rules for generation-skipping transfers. |
| 200447029(PDF, 38K) |
7/27/2004 |
| 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 an allocation of Taxpayer’s generation-skipping transfer (GST) tax exemption. |
| 200447028(PDF, 23K) |
11/19/2004 |
| Requesting permission to change an accounting period, for federal income tax purposes under Form 1128. Requesting that the Form 1128 be considered timely filed under the authority contained in section 301.9100-3 of the Procedure and Administration Regulations. |
| 200447027(PDF, 61K) |
7/13/2004 |
| Requesting 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). |
| 200447026(PDF, 26K) |
7/27/2004 |
| Requesting a ruling on certain federal income tax consequences of a proposed transaction. |
| 200447025(PDF, 22K) |
7/21/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200447024(PDF, 23K) |
7/22/2004 |
| Requesting a ruling to be granted an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447023(PDF, 23K) |
7/22/2004 |
| Requesting a ruling to be granted an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447022(PDF, 23K) |
7/22/2004 |
| Requesting a ruling to be granted an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447021(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447020(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447019(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447018(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447017(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447016(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447015(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447014(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447013(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447012(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447011(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447010(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447009(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447008(PDF, 23K) |
7/22/2004 |
| Requesting a ruling for an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200447007(PDF, 20K) |
7/20/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200447006(PDF, 24K) |
7/28/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200447005(PDF, 26K) |
7/27/2004 |
| Requesting a ruling for an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes. |
| 200447004(PDF, 72K) |
7/27/2004 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200447003(PDF, 25K) |
7/28/2004 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200447002(PDF, 39K) |
7/15/2004 |
| Requesting a ruling concerning the generation-skipping transfer (GST) tax consequences of a proposed conversion of a trust. |
| 200447001(PDF, 22K) |
7/7/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200446033(PDF, 412K) |
11/9/2004 |
| Issues: (1) Whether X's administration of a payroll deduction plan that allows employees to contribute to a hospital industry political action committee described in section 527 of the Code constitutes participation or intervention in a political campaign prohibited by section 501(c)(3). (2) If X has intervened in a political campaign, should the excise tax under section 4955 pf the Code be imposed. |
| 200446032(PDF, 437K) |
8/19/2004 |
| Request for a private letter ruling regarding the applicability of section 408(m) of the Internal Revenue Code to investments in units in an investment trust being formed made by individual retirement accounts described in section 408(a) and by individually-directed accounts maintained under plans qualified under section 401(a). |
| 200446031(PDF, 198K) |
8/17/2004 |
| Request for a ruling to waive the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200446030(PDF, 199K) |
8/19/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200446029(PDF, 256K) |
8/17/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200446028(PDF, 231K) |
8/17/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200446027(PDF, 204K) |
8/2/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200446026(PDF, 343K) |
8/19/2004 |
| Request for letter rulings under sections 401(a) and 402 of the Internal Revenue Code. |
| 200446025(PDF, 14K) |
7/26/2004 |
| A final adverse letter ruling with respect to a claim of exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200446024(PDF, 106K) |
11/12/2004 |
| Issues: (1) Whether the costs incurred by Company’s merchandising departments are mixed service costs as defined by § 1.263A-1(e)(4)(ii)(C) of the Income Tax Regulations. (2) Whether Company is entitled to relief under § 7805(b) of the Internal Revenue Code. |
| 200446023(PDF, 22K) |
7/9/2004 |
| Issue: When does Air Carrier incur an obligation to report and deposit the tax imposed by § 4261 of the Internal Revenue Code under the circumstances described below? |
| 200446022(PDF, 17K) |
7/1/2004 |
| Issue: Whether Y is sport fishing equipment for purposes of the tax imposed by § 4161. |
| 200446021(PDF, 73K) |
8/6/2004 |
| Issues: (1) Whether the period of limitations for an issuer of bonds to bring suit to recover an overpayment of an arbitrage rebate paid to the Service is the two-year period under I.R.C. § 6532(a) or the general six-year period under 28 U.S.C. §§ 2401 and 2501? (2) If we conclude under Issue 1 that the general six-year period applies, when does the period of limitations for bringing suit to recover an overpayment of an arbitrage rebate begin? |
| 200446020(PDF, 59K) |
7/26/2004 |
| Requesting rulings regarding the income, estate, gift and generation-skipping transfer tax consequences of modifying a trust. |
| 200446019(PDF, 59K) |
7/26/2004 |
| Requesting rulings regarding the income, estate, gift and generation-skipping transfer tax consequences of modifying a trust. |
| 200446018(PDF, 75K) |
7/1/2004 |
| Requesting rulings regarding the income, estate, gift and generation-skipping transfer tax consequences of a prpoesed transaction. |
| 200446017(PDF, 76K) |
7/1/2004 |
| Requesting rulings regarding the income, estate, gift and generation-skipping transfer tax consequences of a prpoesed transaction. |
| 200446016(PDF, 83K) |
7/1/2004 |
| Requesting rulings regarding the income, estate, gift and generation-skipping transfer tax consequences of a prpoesed transaction. |
| 200446015(PDF, 18K) |
7/20/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200446014(PDF, 21K) |
7/16/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200446013(PDF, 39K) |
7/23/2004 |
| Requesting consent to revoke a previous election under section 4982(e)(4)(A) of the Internal Revenue Code (Code). Additionally a request that the calculation of each of the required distributions of capital gain net income, net gain or loss from foreign currency transactions and passive foreign investment companies held for which the funds have or will make an election under section 1296(k) ("PFIC"), for purposes of calculating the required distributions under sections 4982(b)(1)(B), 4982(e)(2), 4982(e)(5), and 4982(e)(6), be determined on the basis of capital gains and losses realized and recognized. Finally, a request Year F shall be considered the first taxable year of each Fund in which the election under section 4982(e)(4)(A) will not apply for purposes of determining its losses, as applied to the Fund's computation of investment company taxable income and net capital gains under sections 852(b)(2), 852(b)(3), 852(b)(8), 852(b)(10) as well as section 1.852-11(f) of the Income Tax Regulations (the regulations), the determination of the Fund’s earnings and profits under section 852(c)(2) and section 1.852-11(g) of the regulations, and for purposes of designating capital gain dividends under section 852(b)(3)(C) and section 1.852-11(e) of the regulations. |
| 200446012(PDF, 21K) |
7/16/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200446011(PDF, 38K) |
7/19/2004 |
| Request for rulings regarding certain Federal income tax consequences of a proposed transaction. |
| 200446010(PDF, 28K) |
7/16/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200446009(PDF, 24K) |
7/21/2004 |
| Requesting a ruling that the rental income received is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200446008(PDF, 40K) |
7/20/2004 |
| Requesting 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 Generation-Skipping Transfer (GST) exemption. |
| 200446007(PDF, 27K) |
7/14/2004 |
| Requesting a ruling that the amount treated as a deemed dividend by X and its shareholders is not income to Trust 1 and Trust 2 within the meaning of § 643(b), and that therefore, Trust 1 and Trust 2 will have no obligation to distribute such amount to the income beneficiary to meet the distribution requirements of § 1361(d)(3)(B). |
| 200446006(PDF, 47K) |
7/15/2004 |
| Request for rulings concerning the application of the “proceeds-spent-last” allocation rule set forth in § 1.148-6(d)(3)(i) to proceeds of the Series C Deficit Bonds. |
| 200446005(PDF, 23K) |
7/22/2004 |
| 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 a disregarded entity for federal tax purposes. |
| 200446004(PDF, 23K) |
7/22/2004 |
| Requesting a ruling to be granted an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election under §301.7701-3(c) to be treated as a disregarded entity for federal tax purposes. |
| 200446003(PDF, 47K) |
7/13/2004 |
| 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 generation-skipping transfer exemption and a determination that a previous allocation is deemed void or ineffective. |
| 200446002(PDF, 37K) |
7/15/2004 |
| Requesting a ruling concerning the generation-skipping transfer tax consequences of a proposed conversion of a trust. |
| 200446001(PDF, 41K) |
7/13/2004 |
| Requesting a waiver under section 7702(f)(8) of the Internal Revenue Code for life insurance certificates, issued under a Group Contract, that inadvertently failed to meet the requirements of section 7702 to be considered life insurance contracts, for federal income tax purposes. |
| 200445046(PDF, 45K) |
10/29/2004 |
| Issue: Whether the purchasers of Massachusetts historic rehabilitation tax credits and low-income housing tax credits have made a “payment,” for purposes of § 164(a) of the Internal Revenue Code, when they file their state tax returns and use the purchased credits to reduce their state tax liability. |
| 200445045(PDF, 276K) |
8/11/2004 |
| Requesting advanced approval of grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200445044(PDF, 73K) |
8/10/2004 |
| Request for a waiver of the minimum funding standard. |
| 200445043(PDF, 70K) |
8/10/2004 |
| Request for a waiver of the minimum funding standard. |
| 200445042(PDF, 147K) |
8/10/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3) of the Internal Revenue Code. |
| 200445041(PDF, 304K) |
8/10/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) and section 408(d)(3) of the Internal Revenue Code. |
| 200445040(PDF, 49K) |
8/9/2004 |
| Request for a waiver of the minimum funding standard. |
| 200445039(PDF, 216K) |
8/9/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(B) of the Internal Revenue Code. |
| 200445038(PDF, 245K) |
8/13/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200445037(PDF, 316K) |
8/12/2004 |
| Requesting a letter ruling concerning the federal income tax treatment of certain contributions under section 414(h)(2) of the Internal Revenue Code. |
| 200445036(PDF, 205K) |
8/10/2004 |
| Requesting a letter ruling concerning the federal income tax treatment of certain contributions under section 414(h)(2) of the Internal Revenue Code. |
| 200445035(PDF, 82K) |
8/12/2004 |
| Request for a waiver of the minimum funding standard. |
| 200445034(PDF, 83K) |
8/12/2004 |
| Request for a waiver of the minimum funding standard. |
| 200445033(PDF, 71K) |
8/12/2004 |
| Request for a waiver of the minimum funding standard. |
| 200445032(PDF, 71K) |
8/12/2004 |
| Request for a waiver of the minimum funding standard. |
| 200445031(PDF, 219K) |
8/10/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200445030(PDF, 227K) |
8/10/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200445029(PDF, 191K) |
8/9/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200445028(PDF, 98K) |
8/10/2004 |
| Request for a waiver of the minimum funding standard. |
| 200445027(PDF, 144K) |
8/11/2004 |
| Requesting waivers of the 10 percent excise tax due under section 4971(f)(1) and the 100 percent excise tax due under section 4971(f)(2) of the Internal Revenue Code with respect to liquidity shortfalls. |
| 200445026(PDF, 164K) |
7/29/2004 |
| Issues: (1) What retail selling prices must a merchant use to ensure that the retail method of accounting sanctioned in §1.471-8 clearly reflects income? (2) Given the revenue agent’s determination that Taxpayer did not apply the retail method properly and did not maintain the inventory records required by §1.471-8, should the national office revoke Taxpayer's ruling retroactively? |
| 200445025(PDF, 189K) |
8/4/2004 |
| Issues: (1) Whether income realized on the sale of Corp A stock by Trust 1 on Date 1, is includible in the gross income of A as the owner of the trust, or whether Trust 1 was a nongrantor trust by reason of the amendments made to the trust documents on Date 2, and if so, the tax consequences of the conversion of the trust from grantor to nongrantor status? (2) Whether income realized on the sale of Corp A stock by Trust 3 on Date 1, is includible in the gross income of A as the owner of the trust, or whether Trust 3 was a nongrantor trust by reason of the amendments made to the trust documents on Date 2, and if so, the tax consequences of the conversion of the trust from grantor to nongrantor status? (3) Whether income realized by Foundation 1 on the sale of Corp A stock on Date 1 is includible in the gross income of A? (4) Whether income was realized by Trust 4 on the sale of Corp A stock, and if so, was it includible in the gross income of A? (5) Whether A satisfied all the information reporting requirements with respect to his interests in Trust 1, Trust 3, Foundation 1, and Trust 4? |
| 200445024(PDF, 43K) |
7/12/2004 |
| Request for a ruling concerning the income and gift tax consequences of a proposed donation. |
| 200445023(PDF, 44K) |
7/12/2004 |
| Request for a ruling concerning the income and gift tax consequences of a proposed donation. |
| 200445022(PDF, 31K) |
7/13/2004 |
| Request for an extension of time under Treas. Reg. § 301.9100-3 to file certain statements described in § 1.1503-2A and § 1.1503-2. |
| 200445021(PDF, 20K) |
7/7/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200445020(PDF, 38K) |
11/12/2003 |
| Requesting a ruling concerning the Federal income tax consequences under § 382 of the Internal Revenue Code of a transaction that involves the restructuring of operations. |
| 200445019(PDF, 31K) |
7/16/2004 |
| Request that an election under § 855(a) of the Internal Revenue Code to treat dividends distributed after the close of a taxable year as having been paid during that taxable year be considered timely filed pursuant to § 301.9100-3 of the Procedure and Administration Regulations. |
| 200445018(PDF, 20K) |
7/15/2004 |
| Requesting permission to change an accounting period, for federal income tax purposes. A request that the Form 1128 be considered timely filed under the authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200445017(PDF, 21K) |
7/21/2004 |
| Requesting permission to change an accounting period, for federal income tax purposes. A request that the Form 1128 be considered timely filed under the authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200445016(PDF, 33K) |
7/20/2004 |
| Request for rulings regarding certain federal income tax consequences of a series of proposed transactions. |
| 200445015(PDF, 55K) |
7/19/2004 |
| Requesting a ruling that certain transfers of interests in partnerships owning low-income housing tax credit property will not result in recapture under § 42(j)(1) of the Internal Revenue Code. |
| 200445014(PDF, 37K) |
7/15/2004 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200445013(PDF, 32K) |
7/8/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested in order to file an election to restore value under § 1.382-8(h) of the Income Tax Regulations |
| 200445012(PDF, 33K) |
7/8/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested in order to file an election to restore value under § 1.382-8(h) of the Income Tax Regulations |
| 200445011(PDF, 28K) |
7/8/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested in order to file an election to restore value under § 1.382-8(h) of the Income Tax Regulations |
| 200445010(PDF, 36K) |
7/12/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file the Agreement to Pay Section 2056A Estate Tax and the Information Statement required under § 20.2056A-4(c)(2)(i)-(iii) of the Estate Tax Regulations. |
| 200445009(PDF, 66K) |
7/16/2004 |
| Requesting rulings concerning the federal income tax consequences of a proposed transaction. |
| 200445008(PDF, 23K) |
7/12/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that Company's presumptively late election under § 1362(a) to be an S corporation will be treated as timely made. |
| 200445007(PDF, 23K) |
7/12/2004 |
| Requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations, for an extension of time to make an election section 754 of the Internal Revenue Code. |
| 200445006(PDF, 23K) |
7/12/2004 |
| Requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations, for an extension of time to make an election section 754 of the Internal Revenue Code. |
| 200445005(PDF, 23K) |
7/12/2004 |
| Requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations, for an extension of time to make an election section 754 of the Internal Revenue Code. |
| 200445004(PDF, 38K) |
7/16/2004 |
| Request for a private letter ruling regarding the application of § 1033 of the Internal Revenue Code to amounts received for the cost of relocating certain equipment. |
| 200445003(PDF, 25K) |
7/26/2004 |
| 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. |
| 200445002(PDF, 47K) |
7/20/2004 |
| Requesting a ruling regarding the proper federal income tax treatment of certain judgment or settlement proceeds attributable to assigned claims. |
| 200445001(PDF, 51K) |
7/16/2004 |
| 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. |
