| 200509034(PDF, 412K) |
12/6/2004 |
| Requesting rulings concerning the application of sections 402(c) and 408(d)(3) of the Internal Revenue Code. |
| 200509033(PDF, 71K) |
12/10/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200509032(PDF, 292K) |
12/8/2004 |
| Requesting a ruling concerning the determination of net unrealized appreciation under section 402(j) of the Internal Revenue Code. |
| 200509031(PDF, 14K) |
12/6/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200509030(PDF, 64K) |
12/6/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200509029(PDF, 64K) |
12/6/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200509028(PDF, 14K) |
12/6/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200509027(PDF, 63K) |
12/6/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200509026(PDF, 15K) |
12/6/2004 |
| Requesting exemption from federal income taxation under section 501(c)(25) of the Internal Revenue Code. |
| 200509025(PDF, 18K) |
12/10/2004 |
| Requesting advance approval of your grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200509024(PDF, 18K) |
12/10/2004 |
| Requesting advance approval of your grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200509023(PDF, 146K) |
11/17/2004 |
| Issues: (1) To what extent is Taxpayer entitled to benefits as a resident of Country A under the Treaty? (2) If it is determined that Taxpayer is entitled to Treaty benefits as a resident of Country A with respect to certain interest income, may the Service deny credits for foreign taxes paid by Taxpayer on or with respect to such income? |
| 200509022(PDF, 145K) |
10/6/2004 |
| Issues: (1) Whether Contingent Debt Instrument A (Instrument A) and Contingent Debt Instrument B (Instrument B), and Corporation A stock and Corporation B stock, respectively, constitute a straddle for purposes of § 1092(c) of the Internal Revenue Code of 1986 (“Code”). This issue raises two threshold questions: (a) Whether Instrument A and Instrument B, issued by Taxpayer in Year 2, constitute “positions” under § 1092(d)(2); and (b) If Instrument A and Instrument B are “positions” under § 1092(d)(2), whether either of those “positions” qualify under § 1092(d)(3)(B)(i)(II)(1999) as “a position with respect to substantially similar or related property (other than stock)” with respect to Corporation A or Corporation B stock held by Taxpayer? (2) Whether payments on Instrument A and Instrument B constitute interest and carrying charges incurred or continued to purchase or carry the Corporation A and Corporation B stock, respectively, for purposes of § 263(g)(2)(A). |
| 200509021(PDF, 24K) |
10/20/2004 |
| Issue: Railroad Retirement Tax Act status. |
| 200509020(PDF, 16K) |
10/19/2004 |
| Issue: Railroad Retirement Tax Act status. |
| 200509019(PDF, 30K) |
11/12/2004 |
| Requesting a ruling regarding the classification of a trust as a liquidating trust under § 301.7701-4(d) of the Procedure and Administration Regulations. |
| 200509018(PDF, 20K) |
11/15/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200509017(PDF, 21K) |
11/12/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 754 of the Internal Revenue Code. |
| 200509016(PDF, 21K) |
11/15/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200509015(PDF, 21K) |
11/15/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200509014(PDF, 32K) |
11/15/2004 |
| Requesting consent to revoke a previous election under section 4982(e)(4)(A) of the Internal Revenue Code. Additionally, that the calculation of each required distribution of capital gain net income under section 4982(b)(1) and (e)(2) be determined on the basis of capital gains and losses and foreign currency gains and losses. |
| 200509013(PDF, 32K) |
11/17/2004 |
| Requesting a ruling that it will not recognize gain under section 852(b)(6) of the Internal Revenue Code of 1986 upon the distribution of appreciated property in redemption of shares upon the demand of a shareholder pursuant to a tender offer. |
| 200509012(PDF, 38K) |
11/17/2004 |
| 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. |
| 200509011(PDF, 38K) |
11/17/2004 |
| 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) tax exemption. |
| 200509010(PDF, 17K) |
11/17/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200509009(PDF, 23K) |
11/16/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be classified as a partnership for federal tax purposes. |
| 200509008(PDF, 27K) |
11/17/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200509007(PDF, 27K) |
11/17/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200509006(PDF, 27K) |
11/17/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200509005(PDF, 35K) |
11/17/2004 |
| Requesting rulings as to: (1) whether vehicle service agreements (VSAs) issued by Company will qualify as insurance contracts for federal income tax purposes, and (2) whether Company will be treated as an insurance company for federal income tax purposes. |
| 200509004(PDF, 24K) |
11/12/2004 |
| Requesting a ruling that loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200509003(PDF, 33K) |
11/18/2004 |
| Requesting an extension of time under §§ 301.9100-1 and -3 of the Procedure and Administration Regulations for Taxpayer to make consent dividend elections pursuant to § 565 of the Internal Revenue Code. |
| 200509002(PDF, 62K) |
10/29/2004 |
| Requesting rulings on the generation-skipping transfer (GST) tax, income tax, gift tax and estate tax consequences of a proposed judicial modification of a trust. |
| 200509001(PDF, 21K) |
3/11/2004 |
| Requesting that the IRS supplement the letter ruling dated November 12, 2003 (PLR-153043-03). |
| 200508031(PDF, 14K) |
12/3/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200508030(PDF, 158K) |
11/30/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3) of the Internal Revenue Code. |
| 200508029(PDF, 179K) |
11/30/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200508028(PDF, 251K) |
11/30/2004 |
| Requesting the following rulings: (1) That the Plan will not lose its tax-qualified status under section 401 (a) of the Code and the trust associated with the Plan will not lose its tax-exempt status under section 501 (a) of the Code merely because of the payment of the Special Contributions or because of the plan amendments authorizing such contributions. (2) That, assuming the requirements for deductibility under section 404 of the Code are otherwise satisfied, employers' contributions to the Pension Fund will not fail to be fully deductible under section 404(a)(l) at the time such contributions are forwarded to the Pension Fund merely because such contributions are in the form of Special Contributions. |
| 200508027(PDF, 278K) |
11/30/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(B) of the Internal Revenue Code. |
| 200508026(PDF, 107K) |
12/2/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200508025(PDF, 193K) |
11/29/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200508024(PDF, 167K) |
12/2/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200508023(PDF, 70K) |
12/2/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200508022(PDF, 14K) |
12/3/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200508021(PDF, 14K) |
12/3/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200508020(PDF, 14K) |
12/3/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200508019(PDF, 14K) |
12/3/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200508018(PDF, 18K) |
11/29/2004 |
| Requesting a ruling under section 509(a)(1) of the Internal Revenue Code. |
| 200508017(PDF, 52K) |
11/9/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200508016(PDF, 29K) |
8/19/2004 |
| Requesting exemption from federal income taxation under section 501(c)(6) of the Internal Revenue Code. |
| 200508015(PDF, 49K) |
12/2/2004 |
| Issues: (1) Whether the tangible personal property, land improvements, and non-residential real property used in connection with operations is includible in MACRS Asset Guideline Class 80.0, “Theme and Amusement Parks” as described in Rev. Proc. 87- 56, 1987-2 C.B. 674, for depreciation purposes. (2) If the tangible personal property, land improvements, and non-residential real property used in connection with operations are not properly includible in MACRS Asset Guideline Class 80.0, how should the assets be treated for depreciation purposes? |
| 200508014(PDF, 18K) |
4/5/2004 |
| Issue: Is X required to be registered under § 4101(a) of the Internal Revenue Code? |
| 200508013(PDF, 20K) |
11/10/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200508012(PDF, 26K) |
11/10/2004 |
| Requesting inadvertent termination relief under §1362(f) of the Internal Revenue Code. |
| 200508011(PDF, 21K) |
11/15/2004 |
| Requesting permission to revoke an election under § 41(c)(4) of the Internal Revenue Code. |
| 200508010(PDF, 25K) |
11/16/2004 |
| Requesting a ruling that loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200508009(PDF, 31K) |
11/17/2004 |
| Requesting a ruling that no placed-in-service event has occurred with respect to property for purposes of the 10-year holding period requirement for existing buildings under § 42(d)(2)(B)(ii) of the Internal Revenue Code as a result of certain transactions. |
| 200508008(PDF, 25K) |
11/12/2004 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to file the annual certification described in §1.1503-2(g)(2)(vi)(B). |
| 200508007(PDF, 27K) |
11/4/2004 |
| 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. |
| 200508006(PDF, 22K) |
10/29/2004 |
| Requesting a ruling that renunciation of U.S. citizenship (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200508005(PDF, 31K) |
10/25/2004 |
| Requesting a ruling concerning the amended and restated Plan which Employer intends to be an eligible deferred compensation plan under section 457(b) of the Internal Revenue Code of 1986. |
| 200508004(PDF, 20K) |
11/10/2004 |
| Requesting a ruling to be treated as a trust for federal income tax purposes under § 301.7701-4 of the Procedure and Administration Regulations. |
| 200508003(PDF, 23K) |
11/8/2004 |
| 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. |
| 200508002(PDF, 64K) |
9/30/2004 |
| Requesting certain rulings with respect to the tax consequences stemming from certain investments in the shares of certain regulated investment companies for purposes of applying the diversification requirements of section 817(h) of the Internal Revenue Code. |
| 200508001(PDF, 43K) |
11/16/2004 |
| Requesting rulings that the severance of a trust into an exempt and non-exempt trust for generation-skipping transfer (GST) tax purposes is a qualified severance under § 2642(a)(3) of the Internal Revenue Code, and that, as a result of the severance, a reverse qualified terminable interest property election made under § 2652(a)(3) for the trust will be effective to allocate GST exemption to the exempt trust. |
| 200507023(PDF, 166K) |
11/23/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200507022(PDF, 208K) |
11/23/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200507021(PDF, 389K) |
11/23/2004 |
| Requesting a ruling concerning the proper treatment of certain fees charged in connection with individual retirement arrangements as described in sections 408(a) and 408A of the Internal Revenue Code. |
| 200507020(PDF, 231K) |
11/23/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200507019(PDF, 242K) |
11/29/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200507018(PDF, 139K) |
11/22/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200507017(PDF, 997K) |
11/23/2004 |
| Requesting a ruling regarding the tax consequences of the spin-off of a subsidiary by the parent corporation sponsoring a plan. |
| 200507016(PDF, 999K) |
11/23/2004 |
| Requesting a ruling regarding the tax consequences of the spin-off of a subsidiary by the parent corporation sponsoring a plan. |
| 200507015(PDF, 215K) |
11/23/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200507014(PDF, 85K) |
11/30/2004 |
| Requsting exemption from Federal income tax under the provisions of section 501(c)(7) of the Internal Revenue Code of 1986 and its applicable Income Tax Regulations. |
| 200507013(PDF, 22K) |
11/10/2004 |
| Requesting permission to change an accounting method of recognizing income and expenses for the construction portion of hybrid contracts from an accrual method to the completed contract method. |
| 200507012(PDF, 25K) |
10/29/2004 |
| 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. |
| 200507011(PDF, 20K) |
11/4/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200507010(PDF, 37K) |
10/25/2004 |
| Requesting a ruling concerning the generation-skipping transfer (GST) tax consequences of a proposed conversion of a trust. |
| 200507009(PDF, 38K) |
11/15/2004 |
| Requesting a ruling that the deferred gain that is the subject of a gain recognition agreement filed pursuant to Treas. Reg. § 1.367(a)-8 is not recognized when Taxpayer participates in a reorganization qualifying for nonrecognition treatment under section 368(a)(1)(F). |
| 200507008(PDF, 41K) |
11/10/2004 |
| Requesting a letter ruling on whether X is an instrumentality of a state under Internal Revenue Code (Code) section 3121(b)(7)(F) such that services provided by employees of X are exempt from taxation as employment for purposes of the Old-Age, Survivors, and Disability Insurance (OASDI) portion of Federal Insurance Contributions Act (FICA) taxes. |
| 200507007(PDF, 19K) |
11/8/2004 |
| Requesting a ruling under § 301.9100-3(a) of the Procedure and Administration Regulations to be granted an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200507006(PDF, 36K) |
11/8/2004 |
| Requesting rulings on the following proposed transactions: (1) Foreign Parent will contribute approximately b% of Target’s stock to Forco Sub 1, a newly formed Country B limited company, and approximately c% of Target’s stock to Forco Sub 2, a newly formed Country B limited company. Foreign Parent will directly own all beneficial interests in Forco Sub 1 and Forco Sub 2. (2) Target will transfer its assets to Acquiring in exchange for approximately d shares of Acquiring’s Class A common stock and approximately e shares of Acquiring’s Class B common stock. (3) Target will then dissolve under the laws of State C and will distribute approximately f shares of Acquiring’s Class A common stock to Forco Sub 1 and approximately g shares of Acquiring’s Class A common stock and h shares of Acquiring’s Class B common stock to Forco Sub 2. By operation of law, the contingent liabilities will be assumed by Forco Sub 1 and Forco Sub 2. |
| 200507005(PDF, 35K) |
11/3/2004 |
| Requesting rulings on the following proposed transactions: (i) Distributing will form Controlled with the same capital structure as Distributing (Class A common stock and Class B nonvoting common stock). Distributing will transfer all of the assets of Business B to Controlled in exchange for all of Controlled’s stock (the “Contribution”). Controlled will not assume any liabilities in the Contribution. To facilitate the transition of Business B to Controlled, for a period of not more than a months, Employee C will perform services for both Distributing and Controlled. (ii) Distributing will distribute all of its shares of Controlled’s Class A common stock and Class B common stock to its shareholders pro rata with the Distributing shareholders receiving one Class A share of Controlled on each Class A share of Distributing and one Class B share of Controlled on each Class B share of Distributing (the “Distribution”). |
| 200507004(PDF, 27K) |
10/25/2004 |
| Requesting a ruling that for purposes of section 856(a)(6) and (h)(1)(a) of the Internal Revenue Code, stock of the Taxpayer held by a Charitable Trust is not treated as stock held by an individual under section 542(a)(2) and is not treated as constructively owned by another person under section 544(a)(1). |
| 200507003(PDF, 30K) |
11/4/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code that the termination of an S corporation election was inadvertent. |
| 200507002(PDF, 75K) |
10/28/2004 |
| Requesting rulings regarding the effect of the proposed settlement agreement for federal gift, income and generation-skipping transfer tax purposes. |
| 200507001(PDF, 52K) |
11/9/2004 |
| Requesting rulings under § 7704 of the Internal Revenue Code. |
| 200506038(PDF, 255K) |
11/15/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200506037(PDF, 137K) |
11/17/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200506036(PDF, 135K) |
11/17/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200506035(PDF, 144K) |
11/17/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200506034(PDF, 136K) |
11/17/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200506033(PDF, 171K) |
11/15/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200506032(PDF, 80K) |
11/18/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200506031(PDF, 181K) |
11/17/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200506030(PDF, 170K) |
11/19/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3) of the Internal Revenue Code. |
| 200506029(PDF, 175K) |
11/17/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200506028(PDF, 144K) |
11/18/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200506027(PDF, 132K) |
11/17/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200506026(PDF, 132K) |
11/17/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200506025(PDF, 702K) |
11/18/2004 |
| Requesting rulings under sections 501(c)(6) and 512 of the Internal Revenue Code. |
| 200506024(PDF, 23K) |
7/29/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200506023(PDF, 29K) |
9/3/2004 |
| Issue: Whether the rejection of amended returns attempting to implement a retroactive change in method of accounting without the consent of the Commissioner under § 446(e) of the Internal Revenue Code brings the issue within the scope of Rev. Proc. 2002-18. |
| 200506022(PDF, 24K) |
10/27/2004 |
| Requesting a ruling that loss of U.S. citizenship (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200506021(PDF, 23K) |
10/29/2004 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to file the election and agreement described in §1.1503-2(g)(2)(i) and to file the annual certification described in § 1.1503-2(g)(2)(vi)(B). |
| 200506020(PDF, 23K) |
10/29/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200506019(PDF, 26K) |
10/20/2004 |
| Requesting a ruling under § 1235 of the Internal Revenue Code. |
| 200506018(PDF, 47K) |
10/28/2004 |
| Requesting extensions of time under §§ 2652(a)(3) and 2654 of the Internal Revenue Code, § 20.2056(b)-7(b)(2)(ii) of the Estate Tax Regulations, and § 301.9100-1 of the Procedure and Administration Regulations to sever the qualified terminable interest property (“QTIP”) portion of Trust into exempt and non-exempt trusts for purposes of the Generation-Skipping Transfer (“GST”) Tax and to make a “reverse” QTIP election with respect to the exempt trust. |
| 200506017(PDF, 56K) |
10/29/2004 |
| Requesting a revised schedule of ruling amounts pursuant to section 1.468A-3(i)(2) of the Income Tax Regulations. |
| 200506016(PDF, 18K) |
11/4/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200506015(PDF, 31K) |
11/5/2004 |
| Requesting a letter ruling under section 6041 of the Internal Revenue Code. |
| 200506014(PDF, 26K) |
11/2/2004 |
| Requesting the revocation of an election under section 4982(e)(4)(A) of the Internal Revenue Code. |
| 200506013(PDF, 27K) |
10/29/2004 |
| Requesting rulings as to certain federal income tax consequences of a proposed transaction. |
| 200506012(PDF, 23K) |
10/29/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200506011(PDF, 41K) |
10/26/2004 |
| Requesting rulings concerning the following proposed transactions. (i) Controlled will be recapitalized to increase its outstanding shares of stock to match the total outstanding shares of stock of Distributing. Taxpayer has represented that the recapitalization will be a tax-free event under § 368(a)(1)(E). (ii) Distributing will distribute all of the Controlled stock pro rata to each of its shareholders (the “Distribution”). (iii) The Outstanding Options will be exchanged as described below. Outstanding Options that are incentive stock options will be exchanged for new incentive |
| 200506010(PDF, 23K) |
10/29/2004 |
| Requesting a ruling under §' 1362(b)(5) of the Internal Revenue Code. |
| 200506009(PDF, 26K) |
10/20/2004 |
| Requesting a ruling under § 1235 of the Internal Revenue Code. |
| 200506008(PDF, 26K) |
10/20/2004 |
| Requesting a ruling under § 1235 of the Internal Revenue Code. |
| 200506007(PDF, 38K) |
10/29/2004 |
| Requesting a ruling under § 1362(a) of the Internal Revenue Code. |
| 200506006(PDF, 25K) |
11/4/2004 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as a partnership for federal tax purposes. |
| 200506005(PDF, 22K) |
10/19/2004 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as an association taxable as a corporation for federal tax purposes. |
| 200506004(PDF, 33K) |
10/22/2004 |
| Requesting rulings that the income of Council is excludible from gross income under § 115(1) of the Internal Revenue Code and that charitable contributions to Council are deductible by the donors to the extent provided by § 170(a) of the Code. |
| 200506003(PDF, 32K) |
10/28/2004 |
| 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 make an allocation of Taxpayer’s generation-skipping transfer (GST) tax exemption. |
| 200506002(PDF, 26K) |
11/4/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be classified as an association taxable as a corporation for federal tax purposes. |
| 200506001(PDF, 22K) |
10/8/2004 |
| Requesting a ruling that loss of U.S. lawful permanent residence (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. |
| 200505032(PDF, 27K) |
11/10/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200505031(PDF, 203K) |
11/8/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200505030(PDF, 598K) |
11/12/2004 |
| Requesting letter rulings under sections 2056, 25 18,402 and 457 of the Internal Revenue Code. |
| 200505029(PDF, 189K) |
11/9/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200505028(PDF, 183K) |
11/9/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200505027(PDF, 182K) |
11/10/2004 |
| Requesting an extension of the amortization period for amortizing the unfunded liabilities (described in section 412(b)(2)(B) of the Internal Revenue Code and section 302(b)(2)(B) of the Employee Retirement Income Security Act of 1974. |
| 200505026(PDF, 221K) |
11/8/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200505025(PDF, 19K) |
10/27/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200505024(PDF, 110K) |
7/28/2004 |
| Requesting recognition of exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(6). |
| 200505023(PDF, 63K) |
11/9/2004 |
| Requesting exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200505022(PDF, 59K) |
11/8/2004 |
| Issue: Whether property passing to Trust A, a testamentary trust, qualifies for the estate tax marital deduction under either § 2056(b)(5) or § 2056(b)(7) of the Internal Revenue Code. |
| 200505021(PDF, 22K) |
10/21/2004 |
| Requesting permission to revoke election under § 41(c)(4) of the Internal Revenue Code. |
| 200505020(PDF, 21K) |
10/14/2004 |
| Requesting permission to revoke election under § 41(c)(4) of the Internal Revenue Code. |
| 200505019(PDF, 26K) |
9/21/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200505018(PDF, 23K) |
10/8/2004 |
| Requesting an extension of time to elect to be treated as a disregarded entity under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200505017(PDF, 31K) |
10/18/2004 |
| Requesting an extension of time to make elections under § 42(f)(1) and § 42(g)(1) of the Internal Revenue Code pursuant to § 301.9100-1 of the Procedure and Administration Regulations. |
| 200505016(PDF, 30K) |
10/28/2004 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an election under § 2057(b)(1)(B) of the Internal Revenue Code. |
| 200505015(PDF, 21K) |
10/13/2004 |
| Requesting permission to revoke election under § 41(c)(4) of the Internal Revenue Code. |
| 200505014(PDF, 20K) |
9/20/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200505013(PDF, 25K) |
10/22/2004 |
| Requesting a ruling that income from a trust is excluded from gross income under § 115(1) of the Internal Revenue Code. |
| 200505012(PDF, 34K) |
10/6/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200505011(PDF, 26K) |
9/30/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations 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 § 1362(b)(5) of the Internal Revenue Code. |
| 200505010(PDF, 38K) |
10/14/2004 |
| Requesting rulings under § 368 and § 1361 of the Internal Revenue Code. |
| 200505009(PDF, 56K) |
10/21/2004 |
| Requesting rulings under I.R.C. section 355 for a certain transaction. |
| 200505008(PDF, 49K) |
10/15/2004 |
| Requesting a ruling concerning the deductibility of a charitable bequest under section 2055 of the Internal Revenue Code. |
| 200505007(PDF, 21K) |
10/8/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be classified as an association taxable as a corporation for federal tax purposes. |
| 200505006(PDF, 26K) |
10/20/2004 |
| Requested an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations to file the required Form 970, Application to use LIFO Inventory Method. This request is made in accordance with § 301.9100-3. |
| 200505005(PDF, 28K) |
9/30/2004 |
| Requesting a ruling to determine federal employment tax status with respect to services provided to a federal agency. |
| 200505004(PDF, 37K) |
10/18/2004 |
| Requesting a ruling concerning the federal income tax withholding requirements with respect to payments of lump sum vacation allowances to certain employees of the Taxpayer. |
| 200505003(PDF, 23K) |
10/28/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200505002(PDF, 28K) |
10/28/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code for an inadvertent termination of S election. |
| 200505001(PDF, 28K) |
10/28/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code for an inadvertent termination of S election. |
