| 200524036(PDF, 161K) |
6/17/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200524035(PDF, 198K) |
6/17/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200524034(PDF, 177K) |
6/17/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200524033(PDF, 195K) |
6/17/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200524032(PDF, 234K) |
6/17/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 401(a)(9) of the Internal Revenue Code. |
| 200524031(PDF, 145K) |
6/17/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200524030(PDF, 35K) |
6/17/2005 |
| Requesting rulings under section 4943 of the Internal Revenue Code. |
| 200524029(PDF, 21K) |
6/17/2005 |
| Requesting exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200524028(PDF, 20K) |
6/17/2005 |
| Requesting exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200524027(PDF, 20K) |
6/17/2005 |
| Requesting exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200524026(PDF, 20K) |
6/17/2005 |
| Requesting exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200524025(PDF, 20K) |
6/17/2005 |
| Requesting exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200524024(PDF, 12K) |
6/17/2005 |
| Requesting exemption from income tax under section 501(a) of the Internal Revenue Code. |
| 200524023(PDF, 20K) |
6/17/2005 |
| Requesting exempt status under section 501(c)(3) of the Internal Revenue Code. |
| 200524022(PDF, 13K) |
6/17/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200524021(PDF, 14K) |
6/17/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200524020(PDF, 18K) |
6/17/2005 |
| Requesting a ruling regarding status as an S corporation. |
| 200524019(PDF, 55K) |
6/17/2005 |
| Requesting a ruling that 3 gain recognition agreements filed pursuant to Treas. Reg. §1.367(a)-8 are terminated after distribution of a stock in a transaction described in section 355 of the Internal Revenue Code. |
| 200524018(PDF, 16K) |
6/17/2005 |
| 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. |
| 200524017(PDF, 62K) |
6/17/2005 |
| Requesting a ruling concerning a plan intended to be an eligible deferred compensation plan under section 457(b) and a retirement system under section 3121(b)(7)(F) of the Code. |
| 200524016(PDF, 64K) |
6/17/2005 |
| Requesting a ruling concerning a plan intending to be an eligible deferred compensation plan under section 457(b) of the Internal Revenue Code of 1986 (the Code). In addition a ruling for 2 more plans with intentions as follows: (1) to be a grandfathered 401(k) plan under section 1116(f)(2)(B)(i) of the Tax Reform Act of 1986; (2) to be an eligible deferred compensation plan under section 457(b) and a retirement system for purposes of section 3121(b)(7)(F). |
| 200524015(PDF, 55K) |
6/17/2005 |
| Requesting the following rulings: (1) an agency and subsidiary are instrumentalities for purposes of § 141 of the Internal Revenue Code; (2) income of an agency and subsidiary is excludable from gross income under § 115(l) and (3) the agency’s use of bond proceeds will not constitute use meeting either the private business tests of § 141(b) or the private loan tests of § 141(c). |
| 200524014(PDF, 63K) |
6/17/2005 |
| Requesting the following rulings concerning Trust: 1. Reformation and amendment of Trust to change the place of administration and governing law, and to add a provision specifically authorizing division of Trust into separate trusts and further authorizing transfers of property to charitable organizations during the term of the trust upon the occurrence of a merger or partial merger of the unitrust and remainder interests, will not affect Trust’s status as a charitable remainder untirust within the meaning of § 664(d)(2). 2. For the year or years in which Taxpayer transfers an undivided portion of his unitrust interest to a charitable organization described in §§ 170(b)(1)(A), 170(c), 2055(a), and 2522(a), Taxpayer will be entitled to a charitable income tax deduction under § 170(a)(1) to the extent of the present value of the unitrust interest transferred as of the date of transfer, calculated as provided in §§ 664 and 7520 and § 25.2512-5 of the Gift Tax Regulations. 3. For the year or years in which Taxpayer transfers an undivided portion of his unitrust interest to a charitable organization described in §§ 170(b)(1)(A), 170(c), 2055(a), and 2522(a), Taxpayer will be entitled to a charitable gift tax deduction under § 2522(a) to the extent of the present value of the unitrust interest transferred as of the date of transfer, calculated as provided in §§ 664, 7520, and § 25.2512-5. 4. The division of Trust by Taxpayer, as trustee of Trust, into Trust A and Trust B and the inter vivos distribution to a qualifying charity of the entire corpus of Trust B corresponding to the undivided unitrust interest gifted by Taxpayer will not cause Trust A to cease to be a trust as described in § 664(d)(2). 5. If at the time of any transfers by Taxpayer of an undivided portion of his unitrust interest to a charitable organization described in §§ 170(b)(1)(A), 170(c), 2055(a), and 2522(a), Trust has realized capital gain income in prior years, which income was not included in the unitrust amounts paid to Taxpayer and therefore not recognized by Taxpayer, capital gain will not then be included in Taxpayer’s income PLR-150543-03 4 by the reason of his transfer of a portion of his unitrust interest to a charitable organization. 6. Any gifts by Taxpayer and Trust to Family Foundation, provided that it is then recognized as a tax-exempt organization as described in § 501(c)(3) and as a private operating foundation as described in § 4942(j)(3), will not be treated as direct or indirect acts of self-dealing under § 4941. |
| 200524013(PDF, 49K) |
6/17/2005 |
| Requesting rulings concerning the proposed division of a trust into two separate trusts. |
| 200524012(PDF, 138K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524011(PDF, 137K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524010(PDF, 137K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524009(PDF, 138K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524008(PDF, 139K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524007(PDF, 137K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524006(PDF, 138K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524005(PDF, 138K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524004(PDF, 138K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524003(PDF, 139K) |
6/17/2005 |
| Requesting rulings of a series of transactions under § 301.7701-3 |
| 200524002(PDF, 69K) |
6/17/2005 |
| Requesting rulings concerning the income, gift, estate, and generation-skipping transfer tax consequences of amendments to certain trusts and divisions of these trusts into subtrusts. |
| 200524001(PDF, 28K) |
6/17/2005 |
| Issues: (1) Whether a self-employed individual who is a sole proprietor may deduct, pursuant to I.R.C. § 162(l), insurance costs for the medical care of the sole proprietor and his or her spouse and dependents from the earned income derived from his or her trade or business when the health insurance policy purchased by the sole proprietor is issued in his or her individual name and not in the name of the sole proprietor’s trade or business. (2) Whether a self-employed individual may aggregate the profits and losses of two or more businesses to establish the net income ceiling up to which he or she may claim insurance costs deductions under I.R.C. § 162(l). |
| 200523035(PDF, 47K) |
12/2/2004 |
| Requesting rulings with issues similar to Private Letter Ruling 9750018. |
| 200523034(PDF, 70K) |
3/16/2005 |
| Requesting a waiver of the minimum funding standard. |
| 200523033(PDF, 293K) |
3/15/2005 |
| Requesting rulings under section 404(a)(6) of the Internal Revenue Code. |
| 200523032(PDF, 196K) |
3/18/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200523031(PDF, 210K) |
3/18/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200523030(PDF, 232K) |
3/18/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200523029(PDF, 212K) |
3/15/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3)(A) of the Internal Revenue Code. |
| 200523028(PDF, 217K) |
3/16/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3)(A) of the Internal Revenue Code. |
| 200523027(PDF, 221K) |
3/14/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200523026(PDF, 153K) |
3/15/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200523025(PDF, 620K) |
3/18/2005 |
| Requesting the following rulings: 1. The amounts representing the Plan X transfers that are transferred from Plan X on behalf of and at the direction of a Plan X participant to one of the Plans in order to purchase service credit for the participant in the particular defined benefit governmental plan will not, pursuant to Code section 402, result in ordinary income to the participant under Code section 72 by reason of such transfer. 2. The amounts representing the Plan X transfers that are transferred from Plan X on behalf of and at the direction of a Plan X participant to one of the Plans to purchase service credit on behalf of the participant under the particular defined benefit governmental plan will not constitute either an impermissible actual distribution or a constructive distribution under Code section 401 (k)(2)(B), nor will the Plan X transfers constitute a violation of the separate accounting requirements under section 1.401 (k)-I (e)(3) of the Income Tax Regulations. 3. The amounts representing the Plan X transfers that are transferred from Plan X on behalf of and at the direction of a Plan X participant to one of the Plans in order to purchase service credit for the participant will not constitute either an "annual benefit" within the meaning of Code section 41 5(b)(2)(A), for purposes of determining limitations for defined benefit plans, nor will the Plan X transfer amounts constitute an "annual addition" within the meaning of Code section 41 5(c)(2), for purposes of determining limitations for defined contribution plans. 4. The special rules of Code section 415(n) relating to the purchase of permissive service credit do not apply to the amounts transferred from Plan X. 5. The amounts representing Plan X transfers that are transferred from Plan X on behalf of and at the direction of a participant to a particular defined benefit governmental plan to purchase service credit will not be considered a designated distribution for the year of the transfer subject to withholding requirements under Code section 3405 and tax reporting under Code section 6047(d). |
| 200523024(PDF, 50K) |
3/17/2005 |
| 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). |
| 200523023(PDF, 26K) |
5/4/2004 |
| Issues: (1) Whether the purported loan of HOME Investment Partnerships Act (HOME) funds between General Partner and Taxpayer should be treated as a grant under § 42(d)(5)(A) of the Internal Revenue Code or a loan under § 1.42-3(a) of the Income Tax Regulations. (2) Whether the purported loan of Affordable Housing Program (AHP) funds between General Partner and Taxpayer should be treated as a grant under § 42(d)(5)(A) or a loan under § 1.42-3(a). |
| 200523022(PDF, 20K) |
3/10/2005 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to attach to Taxpayer’s U.S. income tax return the documentation required under Treas. Reg. § 1.1503-2(g)(2)(iii)(B) to rebut the presumption that the transaction was a triggering event within the meaning of Treas. Reg. § 1.1503-2(g)(2)(iii)(A)(5). |
| 200523021(PDF, 30K) |
3/10/2005 |
| Requesting an extension of time under Treas. Reg. §§ 301.9100-1 and 301.9100-3 to attach to Taxpayer’s U.S. income tax return the documentation required under Treas. Reg. § 1.1503-2(g)(2)(vii)(B) and Treas. Reg. § 1.1503- 2(g)(2)(vii)(C). |
| 200523020(PDF, 24K) |
3/10/2005 |
| Requesting an extension of time under Treas. Reg. § 301.9100-1 and -3 to attach to Taxpayer’s U.S. income tax return the documentation required under Treas. Reg. § 1.1503-2(g)(2)(iii)(B) to rebut the presumption that the transaction was a triggering event. |
| 200523019(PDF, 31K) |
3/10/2005 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to file the annual certifications required by Treas. Reg. § 1.1503-2(g)(2)(vi)(B). |
| 200523018(PDF, 22K) |
3/3/2005 |
| Requesting a ruling under § 301.91000-3(a) of the Procedure and Administration Regulations to be granted an extension of time to treat subsidiaries as qualified subchapter subsidiaries under § 1361(b)(3) of the Internal Revenue Code. |
| 200523017(PDF, 16K) |
3/7/2005 |
| Requesting relief under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations for an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200523016(PDF, 13K) |
3/2/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200523015(PDF, 24K) |
3/7/2005 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to perfect a protective election made under § 2032A of the Internal Revenue Code. |
| 200523014(PDF, 18K) |
3/7/2005 |
| Requesting an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be treated as a disregarded entity. |
| 200523013(PDF, 20K) |
3/2/2005 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200523012(PDF, 27K) |
3/3/2005 |
| Requesting rulings that income is excludible from gross income under § 115(1) of the Internal Revenue Code and that there is no requirement to file an annual federal income tax return. |
| 200523011(PDF, 23K) |
2/24/2005 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200523010(PDF, 23K) |
2/24/2005 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200523009(PDF, 18K) |
3/11/2005 |
| Requesting permission to change an accounting period, for federal income tax purposes, through From 1128. |
| 200523008(PDF, 21K) |
3/10/2005 |
| Requesting permission to change an accounting period, for federal income tax purposes, through From 1128. |
| 200523007(PDF, 27K) |
2/24/2005 |
| Requesting a ruling that a partnership will not recognize any discharge of indebtedness income under § 61 of the Internal Revenue Code. |
| 200523006(PDF, 18K) |
3/2/2005 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200523005(PDF, 15K) |
3/1/2005 |
| Requesting permission to revoke an election under § 41(c)(4) of the Internal Revenue Code. |
| 200523004(PDF, 15K) |
3/4/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200523003(PDF, 100K) |
3/8/2005 |
| Requesting rulings regarding the income and estate tax consequences of naming a family-owned trust company as trustee of certain family trusts. |
| 200523002(PDF, 19K) |
3/8/2005 |
| 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. |
| 200523001(PDF, 22K) |
3/3/2005 |
| Requesting inadvertent termination relief under §1362(f) of the Internal Revenue Code. |
| 200522023(PDF, 36K) |
5/27/2005 |
| Requesting Chief Counsel Advice in order to assist in responding to inquiries concerning the federal tax treatment of two legislative proposals in the State of Nevada. |
| 200522022(PDF, 35K) |
2/18/2005 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(6). |
| 200522021(PDF, 39K) |
3/11/2005 |
| Issues: (1) May the Service retain and apply a payment received as a distribution from a Chapter 7 trustee that relates to a tax liability for which the I.R.C. § 6502(a) collection period, including suspensions provided in I.R.C. § 6503, has expired? (2) After a debtor in a Chapter 7 case receives a discharge, does I.R.C. § 6503(h) continue to suspend the I.R.C. § 6502(a) collection period with respect to a claim for tax that is not excepted from discharge until the stay of any act against property of the estate, pursuant to B.C. § 362(a), is lifted? (3) After a debtor in a Chapter 7 case receives a discharge, does I.R.C. § 6503(b) continue to suspend the I.R.C. § 6502(a) collection period with respect to a claim for tax until the stay of any act against property of the estate , pursuant to B.C. § 362(a), is lifted? |
| 200522020(PDF, 17K) |
5/2/2005 |
| Issue: Whether withholding tax is required under § 1445 when a nonresident alien individual disposes of an option to acquire a U.S. real property interest before exercising the option? |
| 200522019(PDF, 22K) |
5/11/2005 |
| Issues: (1) Whether the Internal Revenue Service may update a levy for post-levy accruals of interest and penalties by altering language on the Form 668-C, Final Demand, rather than issuance of a new Form 668-A, Notice of Levy, when the person or levy source who is in possession of the taxpayer’s property or rights to property has failed to surrender it timely. (2) Whether the Service must provide the information required by IRC §§ 6631 and 6751(a) in an updated final demand. |
| 200522018(PDF, 204K) |
3/7/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200522017(PDF, 184K) |
3/8/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200522016(PDF, 22K) |
3/8/2005 |
| Requesting advance approval of grant-making procedures under section 4945(g) of the Internal Revenue Code. |
| 200522015(PDF, 20K) |
3/7/2005 |
| Requesting approval of a proposed 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, 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). |
| 200522014(PDF, 20K) |
3/7/2005 |
| Requesting approval of a proposed 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, 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). |
| 200522013(PDF, 104K) |
2/25/2005 |
| Requesting rulings regarding certain federal income tax consequences of a proposed transaction described within. |
| 200522012(PDF, 66K) |
2/14/2005 |
| Requesting the following rulings: 1) The proposed disclaimers that will be executed by Spouse will be qualified disclaimers under section 2518(b). 2) Family Trust is a qualified beneficiary within the meaning of section 1.401(a)(9)-4, Question and Answer 5. 3) With respect to the portion of IRA payable to the Family Trust, required minimum distributions within the meaning of section 401(a)(9) may be calculated based upon the life expectancy of Spouse using the single life table found at section 1.401(a)(9)-9 of the “Final” Regulations, Question and Answer 1. |
| 200522011(PDF, 23K) |
2/15/2005 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200522010(PDF, 18K) |
3/7/2005 |
| Requesting rulings concerning the federal income tax treatment of payments received as disability retirement. |
| 200522009(PDF, 15K) |
2/22/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200522008(PDF, 30K) |
2/23/2005 |
| Requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations to file the required Forms 970, Application To Use LIFO Inventory Method. |
| 200522007(PDF, 22K) |
2/28/2005 |
| Requesting inadvertent invalid election relief under § 1362(f) of the Internal Revenue Code. |
| 200522005(PDF, 34K) |
3/4/2005 |
| Requesting a ruling under Article 10, Dividends, of the Convention Between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital Gains. |
| 200522005(PDF, 22K) |
2/17/2005 |
| Requesting a ruling under § 1361(e) of the Internal Revenue Code. |
| 200522004(PDF, 22K) |
2/17/2005 |
| Requesting a ruling under § 1361(e) of the Internal Revenue Code. |
| 200522003(PDF, 22K) |
2/17/2005 |
| Requesting a ruling under § 1361(e) of the Internal Revenue Code. |
| 200522002(PDF, 45K) |
2/18/2005 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to sever a trust into an exempt and nonexempt trust for purposes of the Generation- Skipping Transfer (GST) tax and to make a reverse qualified terminable interest property (QTIP) election under § 2652(a)(3) of the Internal Revenue Code with respect to the exempt trust. |
| 200522001(PDF, 15K) |
2/23/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200521037(PDF, 252K) |
3/1/2005 |
| Requesting rulings under section 414(h)(2) of the Internal Revenue Code. |
| 200521036(PDF, 164K) |
3/1/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200521035(PDF, 231K) |
3/4/2005 |
| Requesting a ruling regarding a waiver of the excise tax under section 4980F(c)(4) of the Internal Revenue Code. |
| 200521034(PDF, 201K) |
3/4/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200521033(PDF, 65K) |
2/14/2005 |
| Requesting the following rulings: 1) The proposed disclaimers that will be executed by Spouse will be qualified disclaimers under section 2518(b). 2) Family Trust is a qualified beneficiary within the meaning of section 1.401(a)(9)-4, Question and Answer 5. 3) With respect to the portion of IRA payable to the Family Trust, required minimum distributions within the meaning of section 401(a)(9) may be calculated based upon the life expectancy of Spouse using the single life table found at section 1.401(a)(9)-9 of the “Final” Regulations, Question and Answer 1. |
| 200521032(PDF, 53K) |
2/11/2005 |
| Issue: Whether the costs of terminating a merger paid by Taxpayer are deductible, either as ordinary and necessary business expenses under § 162 of the Internal Revenue Code or as an abandonment loss under § 165, or whether the costs must be capitalized under § 263. |
| 200521031(PDF, 32K) |
2/23/2005 |
| Issue: Whether, under section 5.02(2) of Revenue Procedure 2004-59, 2004-42 I.R.B. 678, a withholding agent participating in the section 1441 Voluntary Compliance Program (VCP) is liable for interest under section 6601 on an amount that it failed to withhold, with respect to a payment, on the due date for filing Form 1042 when (i) it did not receive documentation relating to the payment by the due date for filing Form 1042, (ii) it did not withhold and pay tax at 30 percent under section 1441 by that date, and (iii) it later received documentation establishing either that no tax was imposed on the payment or that a reduced rate of tax was imposed on the payment. |
| 200521030(PDF, 51K) |
4/6/2005 |
| Issue: You have requested advice on how to calculate the assessment statute expiration date (ASED) in a situation where the taxpayer has filed successive bankruptcies. Specifically, you have asked how the ASED should be determined when the Service issues a statutory notice of deficiency while the automatic stay of a bankruptcy case is in effect, the case is dismissed, and the taxpayer commences another bankruptcy case before the expiration of the suspension period provided for by I.R.C. § 6213(f)(1). |
| 200521029(PDF, 19K) |
3/1/2005 |
| Request a ruling under section 501(c)(3) of the Internal Revenue Code. |
| 200521028(PDF, 19K) |
3/1/2005 |
| Requesting a ruling that redemption of a private foundation's common stock will not be an act of self-dealing under section 4941 of the Internal Revenue Code. |
| 200521027(PDF, 11K) |
12/10/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200521026(PDF, 47K) |
2/22/2005 |
| Issue: Whether unpaid interest on the increase in taxpayer's 1988 income tax deficiencies resulting from a Coordinated Examination Program (CEP) Qualified Amended Return (QAR) furnished in 1994 year was accruable in 1994. |
| 200521025(PDF, 25K) |
2/14/2005 |
| Requesting an extension of time under §301.9100-1(c) of the Procedure and Administration Regulations to file a Form 970, Application To Use LIFO Inventory Method. |
| 200521024(PDF, 15K) |
2/23/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200521023(PDF, 18K) |
2/23/2005 |
| Requesting a ruling under section 305 of the Internal Revenue Code. |
| 200521022(PDF, 18K) |
2/11/2005 |
| Requesting an extension of time to make an election under § 42(g)(1) of the Internal Revenue Code pursuant to § 301.9100-1 of the Procedure and Administration Regulations. |
| 200521021(PDF, 45K) |
5/27/2005 |
| Requesting an extension of time, under § 301.9100-1 and -3 of the Procedure and Administration Regulations, to make elections pursuant to § 1045 of the Internal Revenue Code. |
| 200521020(PDF, 17K) |
2/25/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200521019(PDF, 15K) |
2/15/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200521018(PDF, 29K) |
2/24/2005 |
| Requesting the determination that a group of subsidiaries have all joined in the making of an initial consolidated return and a subsequent consolidated return. |
| 200521017(PDF, 16K) |
3/1/2005 |
| Requesting whether Taxpayer qualifies for the excise tax exemptions allowed to state and local governments under §§ 4041(g)(2), 4221(a)(4), 4253(i), and 4483(a) of the Internal Revenue Code. |
| 200521016(PDF, 17K) |
2/14/2005 |
| Requesting a ruling that loss of lawful permanent resident status (expatriation) will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200521015(PDF, 17K) |
3/1/2005 |
| Requesting a ruling that loss of lawful permanent resident status (expatriation) will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200521014(PDF, 50K) |
2/17/2005 |
| 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. |
| 200521013(PDF, 16K) |
2/16/2005 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations for Company to elect under § 1361(b)(3)(B) of the Internal Revenue Code to be treated as a qualified subchapter S subsidiary. |
| 200521012(PDF, 41K) |
2/23/2005 |
| Requesting rulings under sections 933, 3405, 6041, 6041A, and 6047 of the Internal Revenue Code. |
| 200521011(PDF, 32K) |
2/15/2005 |
| Requesting a ruling that, under section 6050S of the Internal Revenue Code a university may report amounts billed for qualified tuition and related expenses (qualified expenses) based on an annual bill that includes charges for qualified expenses as well as other amounts previously billed. |
| 200521010(PDF, 31K) |
2/18/2005 |
| Requesting a ruling that an association is not an instrumentality of a city, for purposes of Section 3121(b)(7) of the Internal Revenue Code (the Code). Section 3121(b)(7) of the Code excepts from “employment” service performed in the employ of, inter alia, any wholly owned instrumentality of any one or more states or political subdivisions thereof, with exceptions not applicable here. |
| 200521009(PDF, 35K) |
2/22/2005 |
| Requesting a ruling concerning the treatment under section 7702 of the Internal Revenue Code of certain life insurance policies. |
| 200521008(PDF, 18K) |
2/14/2005 |
| 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. |
| 200521007(PDF, 26K) |
2/25/2005 |
| Requesting a private letter ruling to allow the taxpayer to revoke the election out of the installment method under § 453(d)(3) of the Internal Revenue Code and § 15a.453-1(d)(4) of the Income Tax Regulations. |
| 200521006(PDF, 17K) |
2/10/2005 |
| Requesting a time extension under section § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c). |
| 200521005(PDF, 27K) |
2/25/2005 |
| Issues: (1) The Trust’s income is excluded from gross income under section 115(1); (2) Employer contributions paid to the Trust are excludable from the gross income of participants under section 106; and (3) Payments made from the Trust are excludable from the gross income of participants, their spouses and dependents under section 105(b). |
| 200521004(PDF, 18K) |
2/14/2005 |
| Requesting that the Form 1128 be considered timely filed under the authority contained in section 301.9100-3 of the Procedure and Administration Regulations. |
| 200521003(PDF, 18K) |
3/1/2005 |
| Requested a ruling on the deductibility of tuition for children as a medical care expense under section 213(a) of the Internal Revenue Code. |
| 200521002(PDF, 41K) |
2/24/2005 |
| Requesting a private letter ruling as to the application of § 1031(a) of the Internal Revenue Code. |
| 200521001(PDF, 24K) |
2/2/2005 |
| Requesting an extension of time under section 301.9100 of the Procedure and Administration Regulations to make a qualified family-owned business election under § 2057( b)(1)(B) of the Internal Revenue Code. |
| 200520040(PDF, 194K) |
2/22/2005 |
| Requesting the following rulings: (1) a waiver of the minimum funding standard and (2) a waiver of the 100 percent tax under section 4971(b) of the Internal Revenue Code. |
| 200520039(PDF, 415K) |
2/22/2005 |
| Requesting a ruling as to whether a certain plan is a governmental plan as defined in section 414(d) of the Internal Revenue Code. |
| 200520038(PDF, 262K) |
2/24/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200520037(PDF, 166K) |
2/24/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200520036(PDF, 884K) |
2/22/2005 |
| Requesting a ruling concerning whether a plan is a governmental plan under section 414(d) of the Internal Revenue Code and the federal income tax treatment of certain contributions to the plan under section 414(h)(2) of the Code. |
| 200520035(PDF, 82K) |
12/3/2004 |
| Requesting an exempt status under I.R.C. § 501(c)(15) of the Internal Revenue Code. |
| 200520034(PDF, 9K) |
2/22/2005 |
| Requesting an exemption under section 501(c)(8) of the Internal Revenue Code. |
| 200520033(PDF, 92K) |
11/15/2004 |
| Issue: The adjustment of an organization's exempt status. |
| 200520032(PDF, 31K) |
12/16/2004 |
| Requesting an exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200520031(PDF, 92K) |
12/7/2004 |
| Issue: The adjustment of an organization's exempt status. |
| 200520030(PDF, 92K) |
8/6/2004 |
| Requesting an exempt status under section 501 (c)(3) of the Internal Revenue Code. |
| 200520029(PDF, 11K) |
2/15/2005 |
| Issue: Railroad Retirement Tax Act Status. |
| 200520028(PDF, 11K) |
2/15/2005 |
| Issue: Railroad Retirement Tax Act Status. |
| 200520027(PDF, 13K) |
1/6/2004 |
| Issue: Railroad Retirement Tax Act Status. |
| 200520026(PDF, 11K) |
1/14/2005 |
| Issue: Railroad Retirement Tax Act Status. |
| 200520025(PDF, 29K) |
10/22/2004 |
| Issue: Whether Taxpayer’s method of valuing animals raised for sale or slaughter under the farm price method complies with the requirement of the Consent Agreement that the valuation of such animals should reflect, on some reasonable basis (such as weight), the fact that the market price of such animals accrues ratably as the animals mature. |
| 200520024(PDF, 17K) |
2/14/2005 |
| Requesting a ruling under sections 877(a)(1), 2107(a)(1) and 2501(a)(3)(A) of the Internal Revenue Code that expatriation did not have as one of its principal purposes the avoidance of United States’ taxes. |
| 200520023(PDF, 62K) |
1/28/2005 |
| Requesting a ruling concerning the generation-skipping transfer (GST) tax consequences of the proposed distributions of a trust. |
| 200520022(PDF, 62K) |
1/28/2005 |
| Requesting a ruling concerning the generation-skipping transfer (GST) tax consequences of the proposed distributions of a trust. |
| 200520021(PDF, 62K) |
1/28/2005 |
| Requesting a ruling concerning the generation-skipping transfer (GST) tax consequences of the proposed distributions of a trust. |
| 200520020(PDF, 18K) |
2/14/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code (regarding a late S corporation election and an accompanying fiscal year election under § 444). |
| 200520019(PDF, 41K) |
2/10/2005 |
| Requesting a revised schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund with respect to a plant. The required information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to section 1.468A-3(h)(2). |
| 200520018(PDF, 41K) |
2/10/2005 |
| Requesting a revised schedule of ruling amounts under 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund with respect to a plant. The required information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to section 1.468A-3(h)(2). |
| 200520017(PDF, 21K) |
2/10/2005 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200520016(PDF, 17K) |
5/20/2005 |
| 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. |
| 200520015(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. |
| 200520014(PDF, 20K) |
2/17/2005 |
| Requesting rulings on the proper Federal income tax treatment of contributions to and benefits paid from a fund and a plan. |
| 200520013(PDF, 30K) |
1/27/2005 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an election to treat a marital trust as two separate trusts under § 26.2652-2(c) of the Generation-Skipping Transfer Tax Regulations. |
| 200520012(PDF, 17K) |
2/2/2005 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election to be classified as a disregarded entity for federal tax purposes. |
| 200520011(PDF, 22K) |
2/18/2005 |
| Requesting rulings on the application of sections 382(l)(3)(C) and 382(h). |
| 200520010(PDF, 44K) |
2/10/2005 |
| Requesting the following rulings: 1. The modification of the Trust and the implementation of the Court’s order modifying the Trust will not result in a transfer by any beneficiary of the Trust that is subject to the gift tax under section 2501. 2. The modification of the Trust and the implementation of the Court’s order modifying the Trust will not cause the Trust to lose its GST tax exempt status under section 26.2601-1 of the Generation-Skipping Transfer Tax Regulations. |
| 200520009(PDF, 44K) |
2/10/2005 |
| Requesting the following rulings: 1. The modification of the Trust and the implementation of the Court’s order modifying the Trust will not result in a transfer by any beneficiary of the Trust that is subject to the gift tax under section 2501. 2. The modification of the Trust and the implementation of the Court’s order modifying the Trust will not cause the Trust to lose its GST tax exempt status under section 26.2601-1 of the Generation-Skipping Transfer Tax Regulations. |
| 200520008(PDF, 31K) |
2/15/2005 |
| Requesting an extension of time under § 2642(g) of the Internal Revenue Code and §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer (GST) exemption. |
| 200520007(PDF, 20K) |
2/15/2005 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to file the election and agreement described in § 1.1503-2(g)(2)(i) and the annual certification described in §1.1503-2(g)(2)(vi). |
| 200520006(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. |
| 200520005(PDF, 34K) |
2/11/2005 |
| Requesting a ruling concerning the proposed amended and restated deferred compensation plan which State X intends 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. |
| 200520004(PDF, 20K) |
2/8/2005 |
| Requesting a ruling under the Internal Revenue Code concerning individual retirement accounts meeting the requirements of section 408. |
| 200520003(PDF, 49K) |
2/14/2005 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer (GST) tax consequences of the proposed division of a trust. |
| 200520002(PDF, 18K) |
2/14/2005 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as a qualified subchapter S subsidiary effective Date 2 under section 1361(b)(3) of the Internal Revenue Code. |
| 200520001(PDF, 23K) |
2/15/2005 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. |
