| 200519091(PDF, 11K) |
11/20/2003 |
| Issue: Railroad Retirement Tax Act Status. |
| 200519090(PDF, 52K) |
2/17/2005 |
| Requesting a waiver of the minimum funding standard. |
| 200519089(PDF, 160K) |
2/18/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200519088(PDF, 25K) |
2/18/2005 |
| 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). |
| 200519087(PDF, 18K) |
7/26/2004 |
| Requesting an exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(8). |
| 200519086(PDF, 19K) |
2/15/2005 |
| Requesting rulings whether the purchase for certain eligible employees of group life insurance coverage with X’s remaining assets and subsequent termination of X will not constitute prohibited inurement under section 501(c)(9) of the Internal Revenue Code nor a disqualified benefit under section 4976 of the Code. |
| 200519085(PDF, 122K) |
12/17/2004 |
| Requesting an exemption from the Federal Income Tax under section 501(c)(7) of the Internal Revenue Code. |
| 200519084(PDF, 93K) |
12/29/2004 |
| Requesting an exemption from the Federal Income Tax under section 501(c)(19) of the Internal Revenue Code. |
| 200519083(PDF, 18K) |
2/18/2005 |
| Requesting a ruling that for exception from filing annual information returns on Form 990, Return of Organization Exempt from Income Tax, by Revenue Procedure 95- 48, 1995-2 C.B. 418. |
| 200519082(PDF, 35K) |
2/17/2005 |
| Requesting rulings under section 4941 of the Internal Revenue Code. |
| 200519081(PDF, 42K) |
1/28/2005 |
| Issues: (1) May the Service refund or return funds to the victim of an embezzler when the embezzler used the funds to make estimated tax payments on the embezzler’s 2001 income tax account? (2) If the funds may be returned, procedurally how should it be accomplished? |
| 200519080(PDF, 35K) |
12/9/2004 |
| Issues: (1) Are the estimated tax remissions that X made during Years 6 through 10, while under its mistaken view that it was subject to tax, payments of estimated tax or deposits in the nature of cash bonds? (2) Does interest accrue on X’s overpayments of estimated tax from the date X made the estimated tax payments, or from the due date of the tax returns that X filed? (3) Were X’s refund claims for tax Years 6 and 7 timely filed? |
| 200519079(PDF, 12K) |
9/23/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519078(PDF, 11K) |
9/26/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519077(PDF, 11K) |
9/30/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519076(PDF, 11K) |
9/30/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519075(PDF, 11K) |
9/30/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519074(PDF, 11K) |
10/7/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519073(PDF, 11K) |
10/22/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519072(PDF, 11K) |
10/22/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519071(PDF, 12K) |
10/31/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519070(PDF, 11K) |
12/16/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519069(PDF, 11K) |
12/16/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519068(PDF, 11K) |
12/16/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519067(PDF, 11K) |
12/17/2003 |
| Issue: Railroad Retirement Tax Act Status |
| 200519066(PDF, 11K) |
1/5/2004 |
| Issue: Railroad Retirement Tax Act Status |
| 200519065(PDF, 11K) |
1/5/2004 |
| Issue: Railroad Retirement Tax Act Status |
| 200519064(PDF, 11K) |
2/4/2005 |
| Issue: Railroad Retirement Tax Act Status |
| 200519063(PDF, 11K) |
1/30/2005 |
| Issue: Railroad Retirement Tax Act Status |
| 200519062(PDF, 12K) |
1/30/2005 |
| Issue: Railroad Retirement Tax Act Status |
| 200519061(PDF, 12K) |
1/30/2005 |
| Issue: Railroad Retirement Tax Act Status |
| 200519060(PDF, 11K) |
1/30/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519059(PDF, 13K) |
1/30/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519058(PDF, 11K) |
2/8/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519057(PDF, 11K) |
2/8/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519056(PDF, 12K) |
2/7/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519055(PDF, 11K) |
2/8/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519054(PDF, 11K) |
2/8/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519053(PDF, 11K) |
1/31/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519052(PDF, 11K) |
1/25/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519051(PDF, 11K) |
1/4/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519050(PDF, 11K) |
1/4/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519049(PDF, 11K) |
2/8/2005 |
| Issue: Railroad Retirement Tax Act Status.. |
| 200519048(PDF, 44K) |
1/27/2005 |
| Requesting advice regarding whether Taxpayer must include in gross income in the year of receipt a lump-sum payment received from X for the sale to X of Taxpayer’s right to receive payments under Conservation Reserve Program (CRP) contracts. |
| 200519047(PDF, 28K) |
2/10/2005 |
| Requesting rulings concerning certain federal income tax consequences of a trust established to pay benefits under a plan, sponsored for the benefit of certain of its current or former employees who qualify as “highly compensated employees” within the meaning of section 414(q) of the Internal Revenue Code. |
| 200519046(PDF, 20K) |
1/27/2005 |
| Requesting an extension of time under Treas. Reg. §301.9100-3 to elect relief from the limitation in §1503 on the use of certain dual consolidated losses. |
| 200519045(PDF, 19K) |
1/27/2005 |
| Requesting an extension of time under Treas. Reg. §301.9100-3 to file the election agreement described in §1.1503-2(g)(2)(i) with respect to dual consolidated losses and annual certification statements described in §1.1503-2(g)(2)(vi)(B). |
| 200519044(PDF, 24K) |
2/10/2005 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200519043(PDF, 32K) |
2/4/2005 |
| 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. |
| 200519042(PDF, 41K) |
2/3/2005 |
| Requesting rulings under §§ 2518 and 2055 of the Internal Revenue Code. |
| 200519041(PDF, 22K) |
3/3/2005 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200519040(PDF, 17K) |
2/7/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200519039(PDF, 15K) |
2/3/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200519038(PDF, 22K) |
2/15/2005 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Requesting an extension of time to file the statement required by § 1.337(d)-2T(c) to recognize some or all of a loss upon the disposition of the stock of a subsidiary. |
| 200519037(PDF, 21K) |
2/3/2005 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to file the following statements: (i) Taxpayer 1 requests relief to file the election and agreement described in §1.1503-2(g)(2)(i) with respect to the dual consolidated loss incurred by Branch in the tax year ended on Date One; (ii) Taxpayer 2 requests relief to file the election and agreement described in § 1.1503-2(g)(2)(i) with respect to the dual consolidated loss incurred by Branch in the tax year ended on Date Two; and (iii) Taxpayer 2 requests relief to file the annual certification described in § 1.1503- 2(g)(2)(vi)(B) for the tax year ended on Date Two, with respect to the dual consolidated loss incurred by Branch in the tax year ended on Date One. |
| 200519036(PDF, 19K) |
2/1/2005 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to elect the provisions of Revenue Procedure 2002-23, 2002-1 C.B. 744. |
| 200519035(PDF, 25K) |
12/29/2004 |
| Requesting rulings under section 162(m) of the Internal Revenue Code. Specifically, a ruling is requested that the deduction limit of section 162(m) does not apply to "Company", "US Parent", "Acquiror" or their affiliates. |
| 200519034(PDF, 25K) |
12/29/2004 |
| Requesting rulings under section 162(m) of the Internal Revenue Code. Specifically, a ruling is requested that the deduction limit of section 162(m) does not apply to "Company", "US Parent", "Acquiror" or their affiliates. |
| 200519033(PDF, 25K) |
12/29/2004 |
| Requesting rulings under section 162(m) of the Internal Revenue Code. Specifically, a ruling is requested that the deduction limit of section 162(m) does not apply to "Company", "US Parent", "Acquiror" or their affiliates. |
| 200519032(PDF, 30K) |
2/3/2005 |
| 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. |
| 200519031(PDF, 23K) |
2/7/2005 |
| Requesting an extension of time to elect under section 42(g)(3)(D) of the Internal Revenue Code to identify buildings as part of a multiple-building project and to make an election under section 42(g)(1) pursuant to section 301.9100 of the Procedure and Administration Regulations. |
| 200519030(PDF, 34K) |
2/10/2005 |
| Requesting a ruling to treat the gain on the sale of Company stock to the ESOP as nonrecognized under section 1042 of the Internal Revenue Code of 1986. |
| 200519029(PDF, 17K) |
1/14/2005 |
| 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. |
| 200519028(PDF, 22K) |
1/27/2005 |
| Requesting a ruling that a Section 538 Guaranty on two loans from Bank to Taxpayer will not, in and of itself, result in the loans being below market Federal loans under § 42(i)(2)(D) of the Internal Revenue Code. |
| 200519027(PDF, 18K) |
2/1/2005 |
| 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. |
| 200519026(PDF, 23K) |
1/27/2005 |
| Requesting a ruling under section 422 of the Internal Revenue Code. Specifically, a ruling that options granted under Corporation’s Share Option Plan satisfy the requirements of section 422(b)(2) of the Code if such options are granted more than 10 years from the Plan’s initial adoption but within 10 years of the date the Plan was last amended with shareholder consent to increase the number of shares that may be issued under the Plan. |
| 200519025(PDF, 59K) |
1/27/2005 |
| Requesting a waiver under §§ 101(f)(3)(H) and 7702(f)(8) of the Internal Revenue Code for life insurance contracts that inadvertently failed to meet the requirements of §101(f) or § 7702, as applicable. |
| 200519024(PDF, 26K) |
2/9/2005 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to file agreements described in Treas. Reg. § 1.1503-2(g)(2)(i) (“2(g)(2)(i) agreements”) and to file annual certifications described in Treas. Reg. § 1.1503-2(g)(2)(vi)(B). |
| 200519023(PDF, 19K) |
1/27/2005 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be initially disregarded as an entity separate from its owner for federal tax purposes under § 301.7701-3(c). |
| 200519022(PDF, 33K) |
2/7/2005 |
| Requesting a ruling concerning whether an eligible plan, constitutes an eligible deferred compensation plans within the meaning of section 457 of the Internal Revenue Code of 1986 and the Income Tax Regulations thereunder. |
| 200519021(PDF, 33K) |
2/7/2005 |
| Requesting a ruling concerning whether an eligible plan, constitutes an eligible deferred compensation plans within the meaning of section 457 of the Internal Revenue Code of 1986 and the Income Tax Regulations thereunder. |
| 200519020(PDF, 33K) |
2/7/2005 |
| Requesting a ruling concerning whether an eligible plan, constitutes an eligible deferred compensation plans within the meaning of section 457 of the Internal Revenue Code of 1986 and the Income Tax Regulations thereunder. |
| 200519019(PDF, 32K) |
1/24/2005 |
| Requesting rulings concerning the following proposed transaction: (i) Pursuant to a plan of agreement and reorganization, Distributing will cause Controlleds 1, 2, and 3 (each, a “Controlled”) to be incorporated as state Z corporations. Controlleds 1, 2, and 3 will use the cash method of accounting. (ii) Distributing will transfer aa, bb, and cc percent of its business assets relating to business m to each of Controlled 1, 2, and 3, respectively, in exchange solely for all of the outstanding stock of Controlled 1, 2, and 3, respectively. (iii) Distributing will distribute all of the Controlled 1 stock to Shareholders A and B in exchange for all of their Distributing stock; all of the Controlled 2 stock to Shareholders C and D in exchange for all of their Distributing stock; and all of the Controlled 3 stock to Shareholders E and F in exchange for all of their Distributing stock. (iv) Distributing will go out of existence. |
| 200519018(PDF, 16K) |
12/17/2004 |
| 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. |
| 200519017(PDF, 18K) |
12/17/2004 |
| 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. |
| 200519016(PDF, 18K) |
12/17/2004 |
| 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. |
| 200519015(PDF, 18K) |
12/17/2004 |
| 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. |
| 200519014(PDF, 18K) |
12/17/2004 |
| 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. |
| 200519013(PDF, 38K) |
1/19/2005 |
| Requesting an extension of time under section 2642(g) of the Internal Revenue Code and section 301.9100-3 of the Procedure and Administration Regulations to make an allocation of a generation-skipping transfer (GST) exemption. |
| 200519012(PDF, 37K) |
1/19/2005 |
| Requesting an extension of time under section 2642(g) of the Internal Revenue Code and section 301.9100-3 of the Procedure and Administration Regulations to make an allocation of a generation-skipping transfer (GST) exemption. |
| 200519011(PDF, 64K) |
1/13/2005 |
| Requesting rulings under sections 56, 422, 424, 1041, and 2501 of the Internal Revenue Code as they relate to the division of stock options in a property settlement agreement incident to divorce. |
| 200519010(PDF, 20K) |
2/9/2005 |
| 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. |
| 200519009(PDF, 33K) |
1/19/2005 |
| Requesting an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer (GST) exemption. |
| 200519008(PDF, 48K) |
1/19/2005 |
| Requesting an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an allocation of Decedent’s generation-skipping transfer (GST) exemption, sever a trust, and make a “reverse” qualified terminable interest property (“QTIP”) election under § 2652(a)(3). |
| 200519007(PDF, 27K) |
3/7/2005 |
| Requesting a ruling under Treas. Reg. § 1.985-1(b)(1)(iii) that subsidiary real estate investment trusts may use a currency other than the U.S. dollar as their functional currency. |
| 200519006(PDF, 69K) |
1/27/2005 |
| Requesting certain Generation-Skipping Transfer (GST) tax rulings. |
| 200519005(PDF, 34K) |
2/2/2005 |
| Requesting rulings on the proper treatment of certain inter-company receivables under sections 956 and 1442 of the Internal Revenue Code. |
| 200519004(PDF, 41K) |
12/28/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to sever the Marital Trust into the GST Exempt Marital Trust and the GST Nonexempt Marital Trust under § 26.2654-1(b)(1) of the Generation-Skipping Transfer Tax (GST) 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 GST Exempt Marital Share. The |
| 200519003(PDF, 15K) |
2/7/2005 |
| Requesting permission to revoke an election under section 41(c)(4) of the Internal Revenue Code. |
| 200519002(PDF, 26K) |
1/19/2005 |
| Requesting a ruling as to whether a city is required to file information returns for property, sales, and food and beverage tax rebate payments made as development incentives. |
| 200519001(PDF, 14K) |
2/9/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200518087(PDF, 160K) |
2/9/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200518086(PDF, 187K) |
2/10/2005 |
| Requesting a waiver of the minimum funding standard. |
| 200518085(PDF, 237K) |
2/10/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200518084(PDF, 226K) |
2/11/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200518083(PDF, 189K) |
2/10/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200518082(PDF, 1122K) |
2/10/2005 |
| Requesting a ruling concerning whether certain plans, and Welfare Plans A through P are church plans under section 414(e) of the Internal Revenue Code |
| 200518081(PDF, 23K) |
2/11/2005 |
| Requesting a ruling concerning the federal tax implications of the following proposed transactions: 1. Whether your creation, ownership, and operation of Y would cause you to lose your status as a tax exempt organization under section 501(c)(13) of the Internal Revenue Code (“Code”). 2. Whether the dividends you receive from Y would be taxable to you as unrelated business income under section 512(b)(1) of the Code. |
| 200518080(PDF, 21K) |
2/9/2005 |
| Requesting advance approval of grant procedures under section 4945(g)(1) and 4945(g)(3) of the Internal Revenue Code. |
| 200518079(PDF, 27K) |
3/29/2005 |
| Issue: Can a Form 872, Consent to Extend the Time to Assess Tax, be accepted via facsimile transmission (fax)? |
| 200518078(PDF, 14K) |
1/6/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200518077(PDF, 11K) |
1/21/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200518076(PDF, 11K) |
1/23/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200518075(PDF, 11K) |
2/11/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200518074(PDF, 11K) |
2/11/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200518073(PDF, 11K) |
12/27/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200518072(PDF, 11K) |
1/4/2005 |
| Issue: Railroad Retirement Tax Act Status. |
| 200518071(PDF, 48K) |
12/20/2004 |
| Issues: (1) In the case where a military employee is married to and filing jointly with a working non-military spouse, should the entire net tax [shown] on the jointly filed account be covered over to [Guam under I.R.C. § 7654 (Internal Revenue Code of 1954),] or should only the tax attributable to the military employee be covered over? (2) Would the definition of the term “Net Collections” as it relates to Section 7654 include the income taxes imposed on the income attributable to the non-military spouse of a jointly-filed return? (3) Does the military member’s State of Legal Residence designation convey to their non-military spouse? |
| 200518070(PDF, 13K) |
1/25/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200518069(PDF, 79K) |
1/18/2005 |
| Requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200518068(PDF, 14K) |
1/24/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200518067(PDF, 19K) |
12/17/2004 |
| Requesting a ruling under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to be granted an extension of time to make an election to be treated as a disregarded entity under § 301.7701-3. |
| 200518066(PDF, 30K) |
1/26/2005 |
| Requesting a ruling regarding the application of section 1033 of the Internal Revenue Code of 1986 to a certain property transaction. Specifically, a ruling that a certain sale of property will be treated for federal income tax purposes as occurring under “condemnation or threat or imminence thereof” within the meaning of section 1033(a)(2)(A) of the Code. |
| 200518065(PDF, 15K) |
1/10/2005 |
| Requesting relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200518064(PDF, 28K) |
1/10/2005 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration regulations to file an election under § 856(l) of the Internal Revenue Code to treat a subsidiary as a taxable REIT subsidiary. |
| 200518063(PDF, 29K) |
1/10/2005 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration regulations to file an election under § 856(l) of the Internal Revenue Code to treat a corporation as a taxable REIT subsidiary. |
| 200518062(PDF, 16K) |
1/31/2005 |
| Requesting supplemental rulings to an initial ruling letter dated August 17, 2004, PLR-119361-04 (the "Prior Letter Ruling"). The Prior Letter Ruling addresses the federal income tax consequences of an Exchange Offer of Units to which section 1032 of the Internal Revenue Code applies. |
| 200518061(PDF, 16K) |
1/14/2005 |
| Requesting a ruling with respect to a proposed transfer of a life insurance policy on the life of Taxpayer, under § 101 of the Internal Revenue Code. |
| 200518060(PDF, 17K) |
1/19/2005 |
| Requesting a ruling under § 45 of the Internal Revenue Code. |
| 200518059(PDF, 14K) |
1/21/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200518058(PDF, 29K) |
1/10/2005 |
| Requesting inadvertent termination relief under §1362(f) of the Internal Revenue Code. |
| 200518057(PDF, 19K) |
1/7/2005 |
| Requesting a ruling that a certain Form 8716, Election To Have A Tax Year Other Than a Required Tax Year, be considered timely filed under the authority of § 301.9100-3 of the Procedure and Administration Regulations. |
| 200518056(PDF, 65K) |
12/20/2004 |
| Requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200518055(PDF, 65K) |
12/20/2004 |
| Requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200518054(PDF, 65K) |
12/20/2004 |
| Requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200518053(PDF, 65K) |
12/20/2004 |
| Requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200518052(PDF, 20K) |
1/12/2005 |
| Requesting inadvertent invalid election relief under § 1362(f) of the Internal Revenue Code. |
| 200518051(PDF, 18K) |
1/11/2005 |
| Requesting a ruling under § 301.9100-3 of the Procedure and Administration Regulations, to be granted an extension of time to elect to be classified as an association taxable as a corporation. |
| 200518050(PDF, 23K) |
1/14/2005 |
| 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. |
| 200518049(PDF, 39K) |
1/27/2005 |
| Requesting a number of rulings under § 7704 of the Internal Revenue Code. |
| 200518048(PDF, 24K) |
1/25/2005 |
| Requesting an extension of time under §§301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Taxpayer to file an election under §1.1502-21(b)(3)(i) of the Income Tax Regulations to relinquish the entire carryback period for the consolidated net operating loss (“CNOL”) of a consolidated group. |
| 200518047(PDF, 58K) |
1/27/2005 |
| Requesting a ruling concerning whether interests in certain real estate qualify as an interest in a closely held business for the purposes of section 6166 of the Internal Revenue Code. |
| 200518046(PDF, 15K) |
1/24/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200518045(PDF, 16K) |
1/18/2005 |
| Requesting a ruling under § 1362(g) of the Internal Revenue Code. |
| 200518044(PDF, 32K) |
1/21/2005 |
| Requesting a ruling under section 884 of the Internal Revenue Code that Taxpayer be treated as a qualified resident of a certain country. |
| 200518043(PDF, 18K) |
12/27/2004 |
| Requesting a ruling under § 301.9100-3 of the Procedure and Administration Regulations, to be granted an extension of time to elect to be classified as an association taxable as a corporation under § 301.7701-3(c). |
| 200518042(PDF, 19K) |
1/18/2005 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending on Date 1, to one ending on Date 2, effective Date 3. X has requested that the Form 1128 be considered timely filed under the authority contained in § 301.9100-3 of the Procedure and Administrative Regulations. |
| 200518041(PDF, 21K) |
1/18/2005 |
| Requesting a ruling that the rental income received from leasing activities is not passive investment income within the meaning of section 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200518040(PDF, 19K) |
1/18/2005 |
| Request for a ruling that payments received for the sale of telecommunication services are not subject to the information reporting requirements under section 6050I of the Internal Revenue Code. |
| 200518039(PDF, 18K) |
1/7/2005 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations, to be classified as an association taxable as a corporation for federal tax purposes. |
| 200518038(PDF, 18K) |
1/13/2005 |
| Requesting a ruling that the rental income received is not passive investment income within the meaning of section 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200518037(PDF, 33K) |
12/20/2004 |
| Requesting rulings regarding the classification of a trust as a partnership under § 301.7701-3(b)(1)(i) of the Procedure and Administration Regulations. |
| 200518036(PDF, 27K) |
1/10/2005 |
| Requesting an extension of time under sections 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an election under section 855(a) of the Internal Revenue Code of 1986 to treat dividends distributed after the close of the taxable year as having been made during that taxable year. |
| 200518035(PDF, 18K) |
1/13/2004 |
| Requesting permission to change an accounting period, for federal income tax purposes. Also that the Form 1128 be considered timely filed under the authority contained in section 301.9100-3 of the Procedure and Administration Regulations. |
| 200518034(PDF, 34K) |
1/24/2005 |
| Requesting rulings of the following proposed transactions: (i) Pursuant to a plan of agreement and reorganization, Distributing will cause Controlleds 1, 2, 3, 4, and 5 (each, a “Controlled”) to be incorporated as state Z corporations. Controlleds 1, 2, 3, 4, and 5 will use the cash method of accounting. (ii) Distributing will transfer aa, bb, cc, dd, and ee percent of its business assets relating to business m to each of Controlled 1, 2, 3, 4, and 5, respectively, in exchange solely for all of the outstanding stock of Controlled 1, 2, 3, 4, and 5, respectively. (iii) Distributing will distribute all of the Controlled 1 stock to Shareholders A and B in exchange for all of their Distributing stock; all of the Controlled 2 stock to Shareholders C and D in exchange for all of their Distributing stock; all of the Controlled 3 stock to Shareholders E and F in exchange for all of their Distributing stock; all of the Controlled 4 stock to Shareholders G and H for all of their Distributing stock; and all of the Controlled 5 stock to Shareholders I and J in exchange for all of their Distributing stock. (iv) Distributing will go out of existence. |
| 200518033(PDF, 33K) |
2/4/2005 |
| Requesting a ruling that a mortgage loan to be secured by an acute care hospital to be constructed in a certain city and to be insured under a federal program will constitute an obligation principally secured by an interest in real property within the meaning of section 860G of the Internal Revenue Code of 1986. |
| 200518032(PDF, 21K) |
1/19/2005 |
| Requesting an extension of time under section 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 under section 1362(b)(5) of the Internal Revenue Code. |
| 200518031(PDF, 18K) |
12/27/2004 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200518030(PDF, 16K) |
1/7/2005 |
| Requesting an extension 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. |
| 200518029(PDF, 18K) |
12/17/2004 |
| 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. |
| 200518028(PDF, 18K) |
12/17/2004 |
| 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. |
| 200518027(PDF, 18K) |
12/17/2004 |
| 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. |
| 200518026(PDF, 18K) |
12/17/2004 |
| 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. |
| 200518025(PDF, 18K) |
12/17/2004 |
| 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. |
| 200518024(PDF, 18K) |
12/17/2004 |
| 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. |
| 200518023(PDF, 18K) |
12/17/2004 |
| 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. |
| 200518022(PDF, 18K) |
12/17/2004 |
| 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. |
| 200518021(PDF, 20K) |
1/14/2005 |
| 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. |
| 200518020(PDF, 26K) |
1/26/2005 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200518019(PDF, 20K) |
1/7/2005 |
| 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. |
| 200518018(PDF, 24K) |
1/3/2005 |
| Requesting rulings under § 1362(b)(5) of the Internal Revenue Code (regarding a late S corporation election and a concomitant fiscal year election under § 444), and § 301.9100-1(c) of the Procedure and Administration Regulations (regarding a late qualified subchapter S subsidiary (QSub) election). |
| 200518017(PDF, 34K) |
1/3/2005 |
| Requesting certain rulings regarding the proper federal tax treatment of attorneys’ fees paid in connection with the settlement of a certain “opt-out” class action lawsuit under sections 61 and 6041 of the Internal Revenue Code. |
| 200518016(PDF, 25K) |
1/18/2005 |
| Requesting a ruling under section 47 of the Internal Revenue Code regarding whether amounts expended to replace an exterior stair attached to a building are included within “qualified rehabilitation expenditures” for purposes of § 47. |
| 200518015(PDF, 43K) |
12/22/2004 |
| Requesting a letter ruling concerning whether Taxpayer has to include certain surcharges it collects from its customers for a city for undergrounding costs, in income under § 61 of the Internal Revenue Code, or, if such amounts are includable, whether Taxpayer is entitled to an offsetting deduction under § 162 of the Internal Revenue Code based on its payment of such amounts to the city. |
| 200518014(PDF, 38K) |
12/30/2004 |
| Requesting a ruling regarding the taxability of a payment received and the deductibility of that payment. |
| 200518013(PDF, 23K) |
1/25/2005 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code that the termination of an S corporation election was inadvertent. |
| 200518012(PDF, 36K) |
12/17/2004 |
| Requesting several rulings concerning the estate tax treatment of property to be disclaimed pursuant to section 2518 of the Internal Revenue Code. |
| 200518011(PDF, 44K) |
1/14/2005 |
| Requesting a ruling under §§ 2057 and 6166 of the Internal Revenue Code. |
| 200518010(PDF, 59K) |
1/21/2005 |
| Requesting certain rulings regarding the treatment of an arrangement being entered into by certain corporations as defined under section 501(c)(3) and others not defined by section 501(c)(3). |
| 200518009(PDF, 19K) |
1/13/2005 |
| Requesting an extension of time under § 301.9100 of the Procedure and Administration Regulations to make an alternate valuation election under § 2032 of the Internal Revenue Code. |
| 200518008(PDF, 38K) |
1/26/2005 |
| Requesting a ruling on the federal income tax consequences of an employer’s deferred compensation plan. |
| 200518007(PDF, 31K) |
1/28/2005 |
| Requesting a ruling that a sixth amendment restating a plan and a first amendment restating a trust constitutes an eligible deferred compensation plan as defined in section 457(b) of the Internal Revenue Code. It is represented that the employer is a political subdivision of a state and is an employer that is a state or local governmental entity as described in section 457(e)(1)(A). |
| 200518006(PDF, 15K) |
1/26/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200518005(PDF, 24K) |
1/13/2005 |
| Requesting a ruling on whether, as a result of Taxpayer’s renunciation and subsequent resignation as co-trustee of certain trusts, the death benefits payable with respect to life insurance policies held by the trusts are includible in Taxpayer’s gross estate under Internal Revenue Code § 2035 or 2042. |
| 200518004(PDF, 20K) |
1/10/2005 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200518003(PDF, 14K) |
1/24/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200518002(PDF, 37K) |
3/9/2005 |
| Issue: May a Chapter 12 plan provide for payment to lower priority creditors before administrative expenses have been paid in full, if the holders of administrative expense claims have not consented to such treatment? |
| 200518001(PDF, 48K) |
3/29/2005 |
| Issues: (1) Is the preparation of an automated substitute for return (ASFR) made under the authority of section 6020(b) considered an examination within the meaning of section 7602? (2) Does the ASFR unit have the authority to adjust its proposed or actual assessments based upon the delinquent original return that is voluntarily submitted by the taxpayer? (3) Whether the Service should process a delinquent original return submitted by a taxpayer or ignore the information contained in that return? (4) Currently, when an assessment based on an ASFR has been made against a taxpayer, and the taxpayer and spouse thereafter file a joint return, the original assessment is abated and a new assessment is made with a collection statute expiration date (CSED) date based upon the new assessment. The IRS Master File does not allow dual CSEDs on a joint return. Is this practice correct? |
| 200517034(PDF, 24K) |
1/31/2005 |
| Requesting a ruling under section 41 2(c)(10) of the Internal Revenue Code. |
| 200517033(PDF, 25K) |
2/2/2005 |
| Requesting advance approval of grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200517032(PDF, 43K) |
1/31/2005 |
| Requesting the following ruling under section 4945 of the Internal Revenue Code and section 53.4945-5 of the Foundation and Similar Excise Taxes Regulations (“Regulations”): If M exercises expenditure responsibility in a manner that would satisfy the requirements of section 53.4945-5 of the regulations, if such requirements applied to M and that M reporting shall fulfill the requirements of that section whether the grant funds originate with M or a U.S. foundation donor. |
| 200517031(PDF, 48K) |
2/2/2005 |
| Requesting rulings under sections 501(c)(3), 4941, and 4943 of the Internal Revenue Code. |
| 200517030(PDF, 24K) |
1/31/2005 |
| Issue: Under section 832(c)(1) of the Internal Revenue Code, is the initial assessment paid to the Fund by Taxpayer deductible as an ordinary and necessary business expense, or is the initial assessment required to be capitalized under section 263(a)? |
| 200517029(PDF, 73K) |
12/27/2004 |
| Requesting a ruling that will waive the 10-year holding period requirement for existing buildings under § 42(d)(2)(B)(ii) of the Internal Revenue Code, pursuant to the authority for the acquisition of certain federally-assisted buildings provided in § 42(d)(6)(C). |
| 200517028(PDF, 64K) |
1/12/2005 |
| Requesting the consent of the Commissioner of the Internal Revenue Service to make a retroactive qualified electing fund election under section 1295 of the Internal Revenue Code and corresponding Treas. Reg. §1.1295-3(f). |
| 200517027(PDF, 20K) |
1/11/2005 |
| Requestinga ruling to revoke an election out of the installment method for the sale of certain properties under § 453 of the Internal Revenue Code and § 15a.453-1(d)(4) of the Income Tax Regulations. |
| 200517026(PDF, 18K) |
1/5/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200517025(PDF, 47K) |
1/4/2005 |
| Requesting an extension under §301.9100 of the Procedure and Administration Regulations to file an election to be treated as a partnership for federal tax purposes. |
| 200517024(PDF, 34K) |
1/7/2005 |
| Requesting a ruling pursuant to § 1504(a)(3)(B) of the Internal Revenue Code to waive the general rule set forth in § 1504(a)(3)(A). |
| 200517023(PDF, 25K) |
1/4/2005 |
| Requesting a ruling pursuant to § 1504(a)(3)(B) of the Internal Revenue Code to waive the general rule set forth in § 1504(a)(3)(A). |
| 200517022(PDF, 37K) |
12/21/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200517021(PDF, 22K) |
1/4/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200517020(PDF, 20K) |
12/20/2004 |
| Requesting rulings regarding the classification of Trust as a partnership under § 301.7701-3(b)(1)(i) of the Procedure and Administration Regulations. |
| 200517019(PDF, 48K) |
12/21/2004 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200517018(PDF, 35K) |
12/21/2004 |
| Requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200517017(PDF, 48K) |
12/21/2004 |
| Requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200517016(PDF, 29K) |
12/21/2004 |
| Requesting rulings under §§ 29 and 702 of the Internal Revenue Code. |
| 200517015(PDF, 42K) |
12/22/2004 |
| 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 under § 301.7701-3(c). |
| 200517014(PDF, 39K) |
12/22/2004 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 642(c)(1) of the Internal Revenue Code. |
| 200517013(PDF, 25K) |
1/10/2005 |
| Requesting relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200517012(PDF, 36K) |
12/22/2004 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 642(c)(1) of the Internal Revenue Code. |
| 200517011(PDF, 25K) |
12/8/2004 |
| Requesting a ruling that rental income is not a passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200517010(PDF, 81K) |
1/3/2005 |
| 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 under § 301.7701-3(c). |
| 200517009(PDF, 22K) |
12/23/2004 |
| Requesting the following rulings: 1. The proposed reformation of Trust will not affect the exempt status of Trust for GST tax purposes. 2. The proposed reformation of Trust will not result in the recognition of gain or loss to Trust or any of Trust’s beneficiaries. |
| 200517008(PDF, 384K) |
12/29/2004 |
| 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. |
| 200517007(PDF, 31K) |
12/29/2004 |
| 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. |
| 200517006(PDF, 169K) |
11/22/2004 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer tax consequences of a proposed merger of trusts. |
| 200517005(PDF, 26K) |
12/23/2004 |
| Requesting a ruling concerning a proposed amended and restated model deferred compensation plan intending to be an updated eligible deferred compensation plan under section 457(b) of the Internal Revenue Code of 1986, as amended under the Economic Growth and Tax Relief Reconciliation Act of 2001. |
| 200517004(PDF, 210K) |
12/23/2004 |
| Requesting a ruling concerning a proposed amended and restated model deferred compensation plan intending to be an updated eligible deferred compensation plan under section 457(b) of the Internal Revenue Code of 1986, as amended under the Economic Growth and Tax Relief Reconciliation Act of 2001. |
| 200517003(PDF, 379K) |
1/11/2005 |
| Requesting rulings regarding the generation-skipping transfer tax consequences of the trustees’ proposed pro rata distribution of a trust's assets into three resulting trusts. |
| 200517002(PDF, 445K) |
12/21/2004 |
| Requesting rulings regarding the generation-skipping transfer tax consequences of a proposed modification of a trust. |
| 200517001(PDF, 398K) |
1/11/2005 |
| Requesting a ruling under section 1362(f) of the Internal Revenue Code. |
| 200516023(PDF, 20K) |
1/28/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200516022(PDF, 51K) |
1/25/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200516021(PDF, 94K) |
1/28/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200516020(PDF, 23K) |
1/27/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(B) of the Internal Revenue Code. |
| 200516019(PDF, 16K) |
1/27/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(B) of the Internal Revenue Code. |
| 200516018(PDF, 16K) |
1/27/2005 |
| Requesting a waiver of the minimum funding standard. |
| 200516017(PDF, 16K) |
1/26/2005 |
| Requesting an exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200516016(PDF, 16K) |
11/8/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200516015(PDF, 16K) |
11/23/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200516014(PDF, 16K) |
12/13/2004 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200516013(PDF, 31K) |
1/3/2005 |
| Requesting an election under § 851(b)(1) of the Internal Revenue Code, to be treated as a regulated investment company, be considered timely filed pursuant to § 301.9100-3 of the Procedure and Administration Regulations. Also a ruling to have timely filed an election under § 855(a) to treat dividends distributed after the close of taxable year as having been paid during that taxable year. |
| 200516012(PDF, 92K) |
1/11/2005 |
| Requesting an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file an election. Also requesting an extension to file a “§1.337(d)-2T(c) statement” under §1.337(d)-2T(c)(3) (the “Election”) that was required to be filed with a consolidated Federal income tax return. |
| 200516011(PDF, 36K) |
12/28/2004 |
| Requesting a letter ruling concerning whether the transfer of a parcel of land is a nonshareholder contribution to capital excludable from Taxpayer’s income under § 118(a) of the Internal Revenue Code. |
| 200516010(PDF, 124K) |
12/16/2004 |
| 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 Generation-Skipping Transfer (GST) exemption. |
| 200516009(PDF, 25K) |
12/13/2004 |
| 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. |
| 200516008(PDF, 21K) |
12/15/2004 |
| Requesting an extension of time under § 301.9100 of the Procedure and Administration Regulations to file an election under § 301.7701-3 to be treated as a corporation for federal tax purposes. |
| 200516007(PDF, 24K) |
12/14/2004 |
| Requesting a ruling under section 877(c) of the Internal Revenue Code of 1986 ("Code") that loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200516006(PDF, 25K) |
12/20/2004 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be classified as an entity disregarded from its owner for federal tax purposes. |
| 200516005(PDF, 43K) |
11/30/2004 |
| Requesting rulings concerning the establishment and operation of a proposed charitable lead trust. |
| 200516004(PDF, 48K) |
1/6/2005 |
| Requesting rulings concerning the disclaimers of a contingent right to receive a remainder interest in certain trusts upon termination of the trusts, including any interest that would be received as a potential appointee of limited power of appointment over two of the trusts. |
| 200516003(PDF, 24K) |
1/4/2005 |
| Requesting an extension under §301.9100 of the Procedure and Administration Regulations to file an election to be treated as disregarded as an entity separate from its owner for federal tax purposes. |
| 200516002(PDF, 73K) |
11/22/2004 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer (GST) tax consequences of a proposed merger of trusts. |
| 200516001(PDF, 64K) |
12/14/2004 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer (GST) tax consequences of a proposed division of a trust. |
| 200515021(PDF, 20K) |
1/19/2005 |
| Requesting a ruling under sections 509(a)(1) and 170(b)(1)(A)(vi) of the Internal Revenue Code. |
| 200515020(PDF, 18K) |
10/20/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200515019(PDF, 47K) |
12/3/2004 |
| Issues: (1) Will members of Company will realize gain or loss under § 1001 on the exchange of Trading Rights for Class B Interests in the First Merger? (2) Will members of Company realize gain or loss under § 1001 on the exchange of their Class B Interests for Trading Permits on the Reorganized Company? |
| 200515018(PDF, 34K) |
11/29/2004 |
| Issue: Whether payments made under a Visiting Fellow award granted to the Taxpayer by the National Institutes of Health Visiting Fellow Program are exempt from U.S. federal income tax under the U.S.-China income tax treaty. |
| 200515017(PDF, 25K) |
12/20/2004 |
| Requesting a ruling under section 877(c) of the Internal Revenue Code of 1986 ("Code") that loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200515016(PDF, 37K) |
12/21/2004 |
| Requesting a ruling that will waive the 10-year holding period for existing buildings under § 42(d)(2)(B)(ii) of the Internal Revenue Code, pursuant to the authority for the acquisition of certain federally-assisted buildings provided in § 42(d)(6)(C). |
| 200515015(PDF, 22K) |
12/23/2004 |
| 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) with respect to a dual consolidated loss. |
| 200515014(PDF, 20K) |
12/20/2004 |
| Requesting permission to revoke an election under § 41(c)(4) of the Internal Revenue Code. |
| 200515013(PDF, 48K) |
12/22/2004 |
| Requesting rulings concerning the following proposed transactions: (i) Distributing will contribute its stock in FSub 3 to newly formed Newco in exchange for all of the Newco stock (the “FSub 3 Contribution”). (ii) Distributing will contribute its Business A assets (except for Asset A), its stock and ownership interests in the Distributing Business A Subsidiaries, and its stock in Newco to Controlled, a newly formed limited liability company that will be a disregarded entity, in exchange for the entire ownership interest in Controlled and the assumption by Controlled of related liabilities (the “First Contribution”). (iii) Controlled will elect to change its entity classification from disregarded entity to limited liability company taxed as a corporation for federal tax purposes (the “Tax Conversion”). (iv) Distributing will distribute the stock of Controlled to Parent (the Distribution”). (v) Parent will contribute its Business A assets to Controlled, and Controlled will assume related liabilities (the “Second Contribution”). Except for (i) Asset B, which will not be transferred in the Second Contribution due to state transfer taxes, and (ii) Asset, which will not be transferred due to significant assignment costs, the Business A assets transferred in the Second Contribution will include all of the property, plant and equipment associated with the Parent Business A operations. (vi) Parent will assume approximately f dollars of Distributing’s debt to Sub 5 (the “Sub 5 Debt”) in constructive exchange for additional Distributing stock (the “Debt Distribution”). |
| 200515012(PDF, 35K) |
12/20/2004 |
| Requesting rulings concerning certain proposed transactions with references to sections 301.7701 o(Income Tax Regulations) and 671-679 (Internal Revenue Code). |
| 200515011(PDF, 48K) |
12/15/2004 |
| Requesting a ruling regarding the application of § 216 of the Internal Revenue Code. |
| 200515010(PDF, 29K) |
12/23/2004 |
| Requesting an extension of time under §301.9100-3 of the Procedure and Administration Regulations to file a “§338(h)(10) election” under §§338(g) and 338(h)(10) of the Internal Revenue Code and §1.338(h)(10)-1(d) of the Income Tax Regulations. |
| 200515009(PDF, 42K) |
12/24/2004 |
| Requesting rulings under §§ 355 and 368 of the Internal Revenue Code. |
| 200515008(PDF, 39K) |
12/21/2004 |
| Requesting rulings concerning the following proposed transactions: (i) Distributing will transfer p of its net worth represented by assets and liabilities of its Business F to Controlled 1 in exchange for k shares of Controlled 1 stock. Immediately thereafter, Distributing will transfer the k shares of Controlled 1 stock to A in exchange for all of A’s k shares of Distributing stock. (ii) Distributing will transfer q of its net worth represented by assets and liabilities of its Business F to Controlled 2 in exchange for n shares of Controlled 2 stock. Immediately thereafter, Distributing will transfer the n shares of Controlled 2 stock to D in exchange for all of D’s n shares of Distributing stock. (iii) Distributing will transfer r of its net worth represented by assets and liabilities of its Business F to Controlled 3 in exchange for o shares of Controlled 3 stock. Immediately thereafter, Distributing will transfer the o shares of Controlled 3 to E in exchange for all of E’s o shares of Distributing stock. |
| 200515007(PDF, 25K) |
12/29/2004 |
| Requesting an extension of time under section 301.9100-1 of the Procedure and Administration Regulations to make an election under section 856(c) of the Internal Revenue Code to be treated as a real estate investment trust (“REIT”). |
| 200515006(PDF, 36K) |
12/9/2004 |
| Requesting the following rulings: (1) the average reasonably expected economic life within the meaning of § 147(b) of the Internal Revenue Code of 1986 (the “1986 Code”) of the Computer Software (as defined below) is determined based on all of the Issuer’s particular facts and circumstances; and (2) the statutory three-year “useful life” of computer software for depreciation purposes under § 167(f)(1) and the administrative guidelines for the treatment of computer software costs under Rev. Proc. 2000-50, 2000-1 C.B. 601, will not bar the Issuer from establishing a longer average reasonably expected economic life of the Computer Software for purposes of § 147(b). |
| 200515005(PDF, 25K) |
12/14/2004 |
| Requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations, to elect to be treated as a disregarded entity for federal tax purposes. |
| 200515004(PDF, 81K) |
12/9/2004 |
| Requesting rulings regarding certain federal income tax consequences of proposed transactions. |
| 200515003(PDF, 22K) |
11/23/2004 |
| Requesting an extension of time, pursuant to § 301.9100-3 of the Procedure and Administration Regulations, to file Form 8832, Entity Classification Election, to elect to be treated as an association taxable as a corporation for federal tax purposes. |
| 200515002(PDF, 31K) |
12/7/2004 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200515001(PDF, 26K) |
1/3/2005 |
| 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. |
