| 200514027(PDF, 210K) |
1/10/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3). |
| 200514026(PDF, 379K) |
1/12/2005 |
| Requesting ruling concerning the federal income tax consequences of the repayment of an exempt loan under section 4975, 415, and 401 (a)(4) of the Internal Revenue Code. |
| 200514025(PDF, 398K) |
1/10/2005 |
| Requesting rulings with regards to section 414(e) and 4980(d)(3) of the Internal Revenue Code. |
| 200514024(PDF, 384K) |
1/11/2005 |
| Requesting rulings under section 414(d) of the Internal Revenue Code. |
| 200514023(PDF, 169K) |
1/10/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200514022(PDF, 445K) |
12/16/2004 |
| Issues: (1) Whether the Fund is a welfare benefit fund under the provisions of Section 41 9 of the Internal Revenue Code (the "Code"). (2) Whether qualified direct costs under the provisions of section 419(c)(3) of the Code only includes claims that are either (a) funded through and paid directly to health care providers and employees by a welfare benefit fund set up by an employer or (b) paid directly to health care providers and employees by the employer from a corporate account and reimbursed by the welfare benefit fund pursuant to a reimbursement agreement entered into between the welfare benefit fund and the employer (i.e. benefits provided by the employer as an agent for the fund). (3) Whether an actuarial certification of a welfare benefit account limit under section 419A(c) of the Code can be based on the total expenditures of the welfare benefit fund and an employer or merely the total expenditures of the welfare benefit fund. |
| 200514021(PDF, 20K) |
1/13/2005 |
| Requesting an exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200514020(PDF, 51K) |
12/29/2004 |
| Issue: Whether quarterly facility fees paid in arrears by the Taxpayer in connection with a revolving credit agreement may be deducted when paid under § 162 of the Internal Revenue Code. |
| 200514019(PDF, 94K) |
4/5/2004 |
| Issue: Does Controlled’s separate return limitation year (“SRLY”) cumulative register under § 1.1502-21T(c)(1) include only the items of income, gain, deduction, and loss generated by Controlled and any applicable subgroup members (as defined in § 1.1502- 21T(c)(2)) or does it also include Distributing’s items of income, gain, deduction, and loss? |
| 200514018(PDF, 23K) |
12/8/2004 |
| Issue: Domestic F Reorganization private letter ruling. |
| 200514017(PDF, 16K) |
6/29/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200514016(PDF, 16K) |
8/4/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200514015(PDF, 16K) |
8/4/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200514014(PDF, 16K) |
8/4/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200514013(PDF, 16K) |
9/13/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200514012(PDF, 16K) |
9/13/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200514011(PDF, 31K) |
1/21/2004 |
| Issue: On the facts described, do the unified partnership audit and litigation procedures of sections 6221 through 6234 of the Internal Revenue Code (“TEFRA”) apply to the present section 501(d) apostolic organization? |
| 200514010(PDF, 92K) |
12/8/2004 |
| Issues: (1) Has Taxpayer adequately substantiated its claim for foreign tax credits with respect to the Taxes? (2) Was Foreign Subsidiary legally liable under Treas. Reg. §1.901-2(f) for Taxes imposed on proceeds from the redemption of Notes by virtue of its acquisition of participation interests relating to the Notes approximately three weeks prior to their redemption? (3) Assuming Taxpayer is eligible to claim indirect credits for the Taxes under section 902 or section 960, do the Taxes belong in the separate category for high withholding tax interest as defined in section 904(d)(2)(B)? |
| 200514009(PDF, 36K) |
12/2/2004 |
| Issues: (1) Under what provision(s) of the Internal Revenue Code should the Taxpayer’s social security benefits be taxed? (2) Whether the Social Security Administration should withhold tax at the rate of 30 percent on the Taxpayer’s social security benefits? (3) Is the Taxpayer entitled to a refund of the 30 percent tax withheld? |
| 200514008(PDF, 124K) |
12/21/2004 |
| Requesting a ruling regarding the application of §1503(d) of the Internal Revenue Code. |
| 200514007(PDF, 25K) |
12/17/2004 |
| Requesting a ruling under section 877(c) of the Internal Revenue Code of 1986 ("Code") that loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. The rulings contained in this letter are based upon information |
| 200514006(PDF, 21K) |
12/15/2004 |
| Requesting a letter ruling supplementing LTR 200445002 dated July 20, 2004. |
| 200514005(PDF, 58K) |
12/6/2004 |
| Requesting rulings regarding the following proposed transactions: (i) Distributing will contribute to newly formed Controlled (a) all of the membership interests in LLC 1, (b) b dollars in cash, and (c) a short-term promissory note having a principal amount of c dollars and bearing a market rate of interest (the “Contributed Note”) solely in exchange for Controlled stock (the “Incorporation”). The cash and Contributed Note will be used to fund working capital and general corporate needs. Pursuant to the same plan, Contributor will transfer all of the membership interests in each of the Owners to Controlled solely in exchange for Controlled stock (the “Contribution”). For federal tax purposes, the contribution by Distributing of the membership interests in LLC 1 will be treated as a contribution of the assets held by LLC 1, and the Contribution will be treated as a transfer by Contributor of the Building. Following step (i), Controlled will be owned d (more than 80) percent by Distributing and e percent by Contributor. (ii) Sub 1 will convert under applicable state law into a limited liability company, LLC 3, whose sole member is LLC 2. (iii) Sub 2 will convert under applicable state law into a limited liability company, LLC 4, whose sole member is LLC 3. (iv) Sub 3 will convert under applicable state law into a limited liability company, LLC 5, whose sole member is LLC 2. (v) Sub 4 will convert under applicable state law into a limited liability company, LLC 6, whose sole member is LLC 2. (vi) Sub 5 will convert under applicable state law into a limited liability company, LLC 7, whose sole member is LLC 6. (vii) Distributing will distribute all of the Controlled stock that it owns to its stockholders, pro rata (the “Distribution”). |
| 200514004(PDF, 23K) |
12/8/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200514003(PDF, 83K) |
12/15/2004 |
| requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200514002(PDF, 30K) |
12/13/2004 |
| Requesting a ruling concerning the transfer of two life insurance policies from one trust to another. |
| 200514001(PDF, 30K) |
12/13/2004 |
| Requesting a ruling concerning the transfer of two life insurance policies from one trust to another. |
| 200513033(PDF, 260K) |
1/6/2005 |
| Requesting relief under sections 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations. |
| 200513032(PDF, 259K) |
1/4/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200513031(PDF, 20K) |
1/4/2005 |
| Requesting a ruling for a contingent set-aside under section 53.4942(a)-3(b)(9) of the Foundation and Similar Excise Taxes Regulations. |
| 200513030(PDF, 37K) |
1/4/2005 |
| Requesting a ruling under section 507(b)(1)(B)(i) of the Internal Revenue Code. |
| 200513029(PDF, 25K) |
1/3/2005 |
| Requesting approval of a proposed set-aside under the suitability test of section 4942(g)(2)(B)(i) of the Internal Revenue Code and section 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations, and a determination that the amount set aside may be treated as a qualifying distribution in the year in which it is set aside (but not in the year in which actually paid). |
| 200513028(PDF, 54K) |
9/15/2004 |
| Issue: Is the loan interest stated in a note executed for an advance from Partnership to the Estate deductible as an expense of administration under § 2053(a)? |
| 200513027(PDF, 98K) |
12/22/2004 |
| Issue: Whether (1) market capitalization on the change date, (2) market capitalization on the change date taking into account certain exceptional circumstances1, if any, in the market, or (3) appraised value based on expert opinion, is the appropriate methodology to determine the fair market value of the stock of Taxpayer and its newly acquired subsidiary, Corp B, for purposes of making the I.R.C. § 382 value determination in this case. |
| 200513026(PDF, 16K) |
6/7/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200513025(PDF, 16K) |
6/30/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200513024(PDF, 16K) |
6/30/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200513023(PDF, 16K) |
11/11/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200513022(PDF, 124K) |
11/15/2004 |
| Issues: (1) Are the series of transactions resulting in the transfer of Building from A to Limited Liability Company considered a disguised sale under § 707(a) of the Internal Revenue Code? (2) Does § 1.701-2 of the Income Tax Regulations apply to the transfer of Building between A and Limited Liability Company. (3) Does the anti-abuse rule found in § 1.704-4(f) apply to the series of transactions resulting in the transfer of Building from A to Limited Liability Company? (4) Is A subject to the penalties under § 6662? |
| 200513021(PDF, 22K) |
12/3/2004 |
| Requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations to elect to be treated as a qualified subchapter S subsidiary (QSub) for federal tax purposes. |
| 200513020(PDF, 31K) |
12/9/2004 |
| Requesting rulings regarding the application of § 216 and § 1032 of the Internal Revenue Code to the Corporation. |
| 200513019(PDF, 25K) |
12/9/2004 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to submit a request to enter into a closing agreement pursuant to Rev. Proc. 2000- 42, 2000-2 C.B. 394. |
| 200513018(PDF, 38K) |
12/14/2004 |
| Requesting the following two rulings under Treas. Reg. § 1.882-5: 1. In determining its interest expense deduction under I.R.C. section 882(c) and Steps 1 and 2 of the interest allocation formula in § 1.882-5, Taxpayer requests permission to elect to determine the value of its U.S. assets under § 1.882-5(b) under the fair market value method while continuing to use the 93 percent fixed ratio to determine the amount of its U.S.-connected liabilities under § 1.882-5(c). Taxpayer requests permission to make the fair market value election and continue its original fixed ratio election on an amended return for the taxable year ended Date B. 2. Under Step 3 of the § 1.882-5 interest allocation formula, Taxpayer requests permission to switch from the adjusted U.S. book liability method in § 1.882- 5(d) to the separate currency pool method provided in § 1.882-5(e) on an amended return for the taxable year ended Date B. |
| 200513017(PDF, 34K) |
12/14/2004 |
| 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. |
| 200513016(PDF, 34K) |
12/14/2004 |
| 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. |
| 200513015(PDF, 24K) |
4/1/2005 |
| Requesting an extension of time to file a Form 1128, Application to Adopt, Change, or Retain a Tax Year, requesting permission to change an accounting period, for federal income tax purposes. |
| 200513014(PDF, 26K) |
11/16/2004 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an election under § 2032A of the Internal Revenue Code. |
| 200513013(PDF, 21K) |
12/2/2004 |
| Requesting an extension of time, under § 301.9100-1 and § 301.9100-3 of the Procedure and Administration Regulations, to file an entity classification election. |
| 200513012(PDF, 34K) |
12/20/2004 |
| Requesting rulings under section 422 of the Internal Revenue Code. Specifically, a ruling that a plan qualifies under section 422 of the Code as an incentive stock option (ISO) plan and that the shareholder approval procedures satisfy the shareholder approval requirements of section 422(b)(1) of the Code. |
| 200513011(PDF, 25K) |
12/3/2004 |
| Requesting a ruling on the tax treatment of damages received in settlement of a lawsuit for faulty construction of a residence. |
| 200513010(PDF, 61K) |
12/6/2004 |
| Requesting a ruling that an undivided fractional interest in rental real property is not an interest in a business entity under § 301.7701- 2(a) of the Procedure and Administration Regulations for purposes of qualification of the undivided fractional interest as eligible replacement property under § 1031(a) of the Internal Revenue Code. |
| 200513009(PDF, 22K) |
12/2/2004 |
| 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. |
| 200513008(PDF, 36K) |
12/8/2004 |
| 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 a generation-skipping transfer (GST) exemption. |
| 200513007(PDF, 21K) |
12/8/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200513006(PDF, 47K) |
11/30/2004 |
| 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 a generation-skipping transfer (GST) tax exemption. |
| 200513005(PDF, 73K) |
11/22/2004 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer (GST) tax consequences of a proposed merger of trusts. |
| 200513004(PDF, 71K) |
11/22/2004 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer (GST) tax consequences of a proposed merger of trusts. |
| 200513003(PDF, 71K) |
11/22/2004 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer (GST) tax consequences of a proposed merger of trusts. |
| 200513002(PDF, 34K) |
12/28/2004 |
| Requesting rulings concerning the treatment of a warehouse line of credit under section 856 of the Internal Revenue Code. |
| 200513001(PDF, 25K) |
12/9/2004 |
| Requesting a ruling under § 1362 of the Internal Revenue Code. |
| 200512035(PDF, 173K) |
12/28/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200512034(PDF, 73K) |
12/29/2004 |
| Requesting a waiver of the minimum funding standard and the 100 percent tax under § 4971(b) of the Internal Revenue. |
| 200512033(PDF, 45K) |
12/29/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200512032(PDF, 78K) |
12/28/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200512031(PDF, 138K) |
12/28/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200512030(PDF, 78K) |
12/28/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200512029(PDF, 133K) |
12/27/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(B) of the Internal Revenue Code. |
| 200512028(PDF, 170K) |
12/27/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200512027(PDF, 34K) |
12/27/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200512026(PDF, 20K) |
12/27/2004 |
| Requesting approval of a set-aside of income under the suitability test of section 4942(g)(2)(B)(i) of the Internal Revenue Code and section 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations. |
| 200512025(PDF, 43K) |
12/28/2004 |
| Requesting rulings concerning the unrelated business income tax treatment of certain activities under sections 511 through 513 of the Internal Revenue Code. |
| 200512024(PDF, 22K) |
12/28/2004 |
| Requesting approval of a set-aside of income under the suitability test of section 4942(g)(2)(B)(i) of the Internal Revenue Code and section 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations. |
| 200512023(PDF, 55K) |
12/30/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(4). |
| 200512022(PDF, 25K) |
1/7/2005 |
| Requesting approval of a proposed set-aside of funds, to be treated as qualifying distributions under section 4942(g)(2) of the Internal Revenue Code. |
| 200512021(PDF, 72K) |
12/29/2004 |
| Issue: Whether the Termination Fee paid by Taxpayer is deductible under § 162 of the Internal Revenue Code or is capitalized under § 263. |
| 200512020(PDF, 111K) |
8/20/2004 |
| Issues: (1) Whether the Underlying Instruments should be characterized as debt or equity. (2) Whether the P.O. Certificates create multiple classes of ownership in the assets of the Primary Trust so that the Primary Trust should be classified as a business entity under Reg. §301.7701-2. (3) What are the consequences of treating the Primary Trust as a business entity under §301.7701-4(c)(1). |
| 200512019(PDF, 18K) |
2/16/2005 |
| Issue: Does future valuing a rebate payment for purposes of computing rebate overpayment constitute the payment of statutory interest. |
| 200512018(PDF, 63K) |
10/25/2004 |
| Issues: (1) Frivolous Return Should the IRS treat “zero returns” claiming nunc pro tunc status as frivolous and subject to the penalty under I.R.C. § 6702? (2) Valid and Processible Return Should the IRS treat these returns as valid for purposes of processing? (3) False or Fraudulent Return Do the returns qualify as false or fraudulent returns such that the IRS could apply the unlimited statute of limitations on assessment found in I.R.C. § 6501(c)(1)? |
| 200512017(PDF, 54K) |
2/18/2005 |
| Issue: Is insurance company W entitled to a restoration of its special estimated tax payments described in § 847(2) as a result of a marginal tax rate increase and certain audit adjustments? |
| 200512016(PDF, 88K) |
2/8/2005 |
| Requesting information concerning the imposition of a penalty under section 6701 of the Internal Revenue Code against appraisers. Specifically, general information regarding: the elements of a section 6701 penalty; the administrative procedures for identifying and asserting a section 6701 penalty; the Service’s authority to impose an injunction under section 7408; the procedures challenging a section 6701 penalty; the availability of Appeals review of a section 6701 penalty; and the application of Circular 230 to appraisers with respect to section 6701 penalties. |
| 200512015(PDF, 16K) |
5/13/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200512014(PDF, 16K) |
5/13/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200512013(PDF, 16K) |
4/4/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200512012(PDF, 16K) |
3/5/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200512011(PDF, 16K) |
9/29/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200512010(PDF, 16K) |
6/6/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200512009(PDF, 16K) |
7/23/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200512008(PDF, 16K) |
8/4/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200512007(PDF, 16K) |
9/28/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200512005(PDF, 56K) |
12/3/2004 |
| Requesting an extension of time under § 2642(g) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations to allow Husband and Wife to allocate their individual generation-skipping transfer (GST) exemptions to transfers. |
| 200512005(PDF, 19K) |
11/22/2004 |
| Requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations to file a Form 3115, Application for Change in Accounting Method, with the Internal Revenue Service (IRS) national office. |
| 200512004(PDF, 42K) |
11/17/2004 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations and section 2642(g) to make an election out of the automatic allocation of generation-skipping transfer (GST) tax under section 2632(c)(5)(A)(i)(II). |
| 200512003(PDF, 42K) |
11/17/2004 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations and section 2642(g) to make an election out of the automatic allocation of generation-skipping transfer (GST) tax under section 2632(c)(5)(A)(i)(II). |
| 200512002(PDF, 91K) |
12/3/2004 |
| Requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200512001(PDF, 108K) |
12/3/2004 |
| Requesting a ruling concerning the conversion of Taxpayer to a corporation “operating on a cooperative basis “ within the meaning of Subchapter T, of the Internal Revenue Code. |
| 200511029(PDF, 125K) |
12/20/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200511028(PDF, 401K) |
12/22/2004 |
| Requesting rulings under sections 72, 402(c) and 41 5(b) of the Internal Revenue Code. |
| 200511027(PDF, 106K) |
12/22/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200511026(PDF, 119K) |
12/20/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200511025(PDF, 86K) |
12/6/2004 |
| Requesting an exempt status under section 501(c) (3) of the Internal Revenue Code. |
| 200511024(PDF, 617K) |
10/27/2004 |
| Issue: Adjustment of an organization's exempt status. |
| 200511023(PDF, 435K) |
5/26/2004 |
| Issue: Adjustment of an organization's exempt status. |
| 200511022(PDF, 141K) |
9/21/2004 |
| Issue: Adjustment of an organization's exempt status. |
| 200511021(PDF, 90K) |
4/5/2004 |
| Requesting an exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200511020(PDF, 77K) |
8/30/2004 |
| Requesting an exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200511019(PDF, 117K) |
3/31/2004 |
| Requesting exemption from income tax under section 501(a) of the Internal Revenue Code as an organization described in I.R.C. section 501(c)(3). |
| 200511018(PDF, 84K) |
8/11/2004 |
| Requesting an exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200511017(PDF, 105K) |
4/27/2004 |
| Requesting an exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200511016(PDF, 110K) |
3/7/2005 |
| Requesting an exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200511015(PDF, 120K) |
12/8/2004 |
| Issues: (1) Whether § 264(a)(1) of the Internal Revenue Code prevents Taxpayer from deducting contributions to a Voluntary Employees Benefit Association Trust (VEBA Trust or VEBA) that are used to purchase life insurance policies, the proceeds from which are used by the VEBA Trust to fund certain post-retirement benefits provided by Taxpayer to its employees? (2) Whether Taxpayer is “directly or indirectly a beneficiary” of the life insurance policies purchased by the VEBA Trust within the meaning of § 264(a)(1)? (3) Whether § 419 allows a deduction for Taxpayer’s contributions to the VEBA Trust to provide a reserve fund for post-retirement medical and life insurance benefits when such reserve funds are invested by the VEBA Trust in life insurance contracts on employees of Taxpayer? |
| 200511014(PDF, 28K) |
11/29/2004 |
| Requesting a ruling regarding the application of § 2632 of the Internal Revenue Code. |
| 200511013(PDF, 57K) |
11/29/2004 |
| Requesting rulings regarding the generation-skipping transfer (GST) tax consequences of Taxpayer’s proposed exercise of a special power of appointment over certain trusts. |
| 200511012(PDF, 35K) |
11/29/2004 |
| Issue: Whether an organization qualifies as a nonprofit educational organization for purposes of exemptions, refunds, and payments related to federal excise taxes under §§ 4041(g), 4221(a)(5), 4253(j), and 6421(c) of the Internal Revenue Code. |
| 200511011(PDF, 21K) |
11/23/2004 |
| Requesting permission to revoke an election under § 41(c)(4) of the Internal Revenue Code. |
| 200511010(PDF, 21K) |
11/22/2004 |
| Requesting permission to revoke an election under § 41(c)(4) of the Internal Revenue Code. |
| 200511009(PDF, 25K) |
11/23/2004 |
| Requesting a ruling that Taxpayer’s § 41(f)(5) controlled group may determine the credit for increasing research activities under the standard method of § 41(a) of the Internal Revenue Code |
| 200511008(PDF, 27K) |
12/6/2004 |
| Requesting a ruling concerning the application of section 382(l)(3)(C). |
| 200511007(PDF, 20K) |
11/24/2004 |
| Requesting a ruling under section 162(m) of the Internal Revenue Code. |
| 200511006(PDF, 50K) |
11/23/2004 |
| Requesting rulings concerning section 7873(a), 7873(b) and 6041 of the Internal Revenue Code. |
| 200511005(PDF, 33K) |
11/22/2004 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200511004(PDF, 34K) |
12/3/2004 |
| Requesting a ruling granting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations to make an election under section 855(a) of the Internal Revenue Code to treat dividends distributed after the close of the taxable year as having been made during that taxable year. |
| 200511003(PDF, 379K) |
10/1/2004 |
| Requesting an exempt status under section 501 (c)(9) of the Internal Revenue Code. |
| 200511002(PDF, 30K) |
11/23/2004 |
| Requesting a ruling under § 43 of the Internal Revenue Code. |
| 200511001(PDF, 24K) |
11/22/2004 |
| Requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make an election to be treated as a homeowners association under § 528 of the Internal Revenue Code. |
| 200510044(PDF, 18K) |
12/16/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200510043(PDF, 381K) |
12/15/2004 |
| Requesting a private letter ruling under section 414(e) of the Internal Revenue Code. |
| 200510042(PDF, 293K) |
12/14/2004 |
| Requesting a ruling concerning the determination of the maximum amount of the deduction allowable under section 404(a)(7) of the Internal Revenue Code. |
| 200510041(PDF, 176K) |
12/15/2004 |
| Requesting an extension for amortizing the unfunded liabilities as described in section 412(b)(2)(B) of the Internal Revenue Code and section 302(b)(2)(B) of the Employee Retirement Income Secutriy Act of 1974. |
| 200510040(PDF, 130K) |
12/15/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200510039(PDF, 291K) |
12/16/2004 |
| Requesting letter rulings concerning the application of section 402(c) of the Internal Revenue Code. |
| 200510038(PDF, 65K) |
12/17/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200510037(PDF, 175K) |
12/14/2004 |
| Requesting a waiver of the 60-day rollover requirement. |
| 200510036(PDF, 174K) |
12/14/2004 |
| Requesting a waiver of the 60-day rollover requirement. |
| 200510035(PDF, 427K) |
12/14/2004 |
| Requesting a ruling with respect to distributions from a retirement plan qualified within the meaning of section 401(a) of the Internal Revenue Code made pursuant to a section 242(b)(2) of the Tax Equity and Fiscal Responsibility Act of 1982 election. |
| 200510034(PDF, 266K) |
12/14/2004 |
| Requesting relief under section 301.9100-3 of the Procedure and Administration Regulations. |
| 200510033(PDF, 254K) |
12/16/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200510032(PDF, 495K) |
12/16/2004 |
| Requesting rulings under sections 402 and 457 of the Internal Revenue Code. |
| 200510031(PDF, 21K) |
11/15/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200510030(PDF, 28K) |
12/17/2004 |
| Requesting a ruling under section 513(d) of the Internal Revenue Code. |
| 200510029(PDF, 31K) |
12/16/2004 |
| Requesting a ruling under section 512 of the Internal Revenue Code. |
| 200510028(PDF, 37K) |
12/17/2004 |
| Issues: (1) Whether the losses resulting from Taxpayer’s liability hedging transactions are capital pursuant to section 1.1221-2 of the Treasury Regulations? (2) Whether Taxpayer’s recognition of the hedging losses in Year 1 clearly reflects income? |
| 200510027(PDF, 25K) |
1/18/2005 |
| Issue: Whether the Service may accept a taxpayer’s declaration of representation to an individual eligible to practice before the IRS if the form, which is otherwise complete, also purports to authorize representation by an individual ineligible to practice before the IRS. |
| 200510026(PDF, 28K) |
11/29/2004 |
| Requesting a ruling regarding the application of § 2632 of the Internal Revenue Code. |
| 200510025(PDF, 20K) |
11/19/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200510024(PDF, 27K) |
11/18/2004 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200510023(PDF, 29K) |
11/18/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200510022(PDF, 55K) |
11/19/2004 |
| Requesting rulings concerning the following proposed transactions: (1) Prior to the Reorganization, Distributing will sell Business B for cash that will be used to redeem the stock owned by Shareholder 17. (2) Distributing then will form three subsidiary corporations, Controlled A, Controlled B, and Controlled C (collectively, the “Controlled Corporations”). (3) Immediately thereafter, Distributing will contribute the Group A Assets to Controlled A, the Group B Assets to Controlled B, and the Group C Assets to Controlled C in exchange for all of the outstanding stock of the Controlled Corporations. (4) In exchange for all of the outstanding stock of Distributing, Distributing will distribute the stock of Controlled A to Shareholder Group A (collectively, Shareholders 1-2), the stock of Controlled B to Shareholder Group B (collectively, Shareholders 3-9), and the stock of Controlled C to Shareholder Group C (collectively, Shareholders 10-16) (the “Distributions”). (5) Distributing will completely liquidate and go out of existence. |
| 200510021(PDF, 24K) |
11/29/2004 |
| 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. |
| 200510020(PDF, 27K) |
11/18/2004 |
| Requesting relief under § 1362(f) of the Internal Revenue Code for an inadvertent termination of S election. |
| 200510019(PDF, 24K) |
10/26/2004 |
| 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. |
| 200510018(PDF, 33K) |
11/23/2004 |
| 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 an allocation of generation-skipping transfer (GST) tax exemption. |
| 200510017(PDF, 83K) |
11/16/2004 |
| Requesting rulings of proposed transactions concerning Treas. Reg. §301.7701-3. |
| 200510016(PDF, 54K) |
11/10/2004 |
| Requesting the following rulings: (1) the income of the Association is excludable from gross income under section 115(1) of the Internal Revenue Code (“Code”); (2) a determination that the Association is an instrumentality within the meaning of Code sections 3121(b)(7) and 3306(c)(7); and (3) that the contributions made to the Association will be deductible by the donors as charitable contributions under section 170(c)(1) of the Code. |
| 200510015(PDF, 25K) |
11/18/2004 |
| Requesting relief for an inadvertent invalid subchapter S election under section 1362(f) of the Internal Revenue Code. |
| 200510014(PDF, 21K) |
11/22/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200510013(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. |
| 200510012(PDF, 39K) |
11/17/2004 |
| Requesting rulings of the following proposed transactions: (i) An agent of Taxpayer will form Holdco as a domestic corporation. (ii) Holdco will form a single-member domestic limited liability company ("LLC"). (iii) Taxpayer will merge into LLC under applicable state law (the "Merger"). In the Merger, Class A Shares will be converted into the right to receive shares of Holdco's sole class of common stock. Class B Shares will be converted into contract rights of LLC (the “Contract Rights”). The Contract Rights will not constitute an equity interest in LLC or Holdco, and will have trading rights identical to the Trading Rights of the Class B shares. (iv) Following the Merger, LLC will distribute certain assets unrelated to Business A and its Sub 1 stock to Holdco. |
| 200510011(PDF, 32K) |
11/18/2004 |
| Requesting relief under section 1362(f) of the Internal Revenue Code. |
| 200510010(PDF, 31K) |
11/18/2004 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make the election not to deduct the additional first year depreciation under § 168(k) of the Internal Revenue Code for certain qualified property placed in service. |
| 200510009(PDF, 35K) |
11/17/2004 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200510008(PDF, 43K) |
11/23/2004 |
| Issue: Whether an adjustment (positive or negative) to the cost of wholesale purchased electricity delivered to Taxpayer during the year will be deemed to be determinable with reasonable accuracy by Taxpayer at year end under the second prong of the all events tests of I.R.C. §§ 461 and 451 when the amount is unknown until a complex calculation is completed by the supplier approximately 75 days after year end. |
| 200510007(PDF, 29K) |
11/23/2004 |
| Requesting an extension of time under Treas. Reg. §301.9100-3 to file: (1) the election statements described in Treas. Reg. §1.1503-2(g)(2)(i); (2) the annual certification statement described in Treas. Reg. §1.1503-2(g)(2)(vi)(B); and (3) the agreement described in Treas. Reg. §1.1503-2(g)(2)(iv)(B)(3)(iii). |
| 200510006(PDF, 24K) |
10/27/2004 |
| 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. |
| 200510005(PDF, 21K) |
10/27/2004 |
| 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. |
| 200510004(PDF, 24K) |
10/28/2004 |
| 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. |
| 200510003(PDF, 24K) |
10/28/2004 |
| 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. |
| 200510002(PDF, 43K) |
11/19/2004 |
| Requesting various rulings relating to a trust’s status as a real estate investment trust (REIT) under section 856 of the Internal Revenue Code. |
| 200510001(PDF, 23K) |
11/23/2004 |
| Requesting a ruling that loss of United States citizenship 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. |
