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Release Date: July 22, 2005 #200529001 - 200529013
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Release Date: July 15, 2005 #200528001 - 200528035
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| 200527026(PDF, 179K) |
7/8/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200527025(PDF, 174K) |
7/8/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200527024(PDF, 191K) |
7/8/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200527023(PDF, 277K) |
7/8/2005 |
| Requesting a ruling concerning the pick up of employee contributions under section 414(h)(2) of the Internal Revenue Code. |
| 200527022(PDF, 22K) |
7/8/2005 |
| Requesting advance approval of grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200527021(PDF, 12K) |
7/8/2005 |
| Requesting an exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200527020(PDF, 39K) |
7/8/2005 |
| Requesting for rulings, as amended, under sections 4941, 4942, and 4945 of the Internal Revenue Code. |
| 200527019(PDF, 19K) |
7/8/2005 |
| Requesting a ruling that X meets the requirements of Rev. Proc. 95-48, 1995-2 C.B. 418, to qualify as an affiliate of a governmental unit and therefore not be required to file Form 990, Return of Organization Exempt from Federal Income Tax. |
| 200527018(PDF, 20K) |
7/8/2005 |
| Requesting advance approval of grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200527017(PDF, 22K) |
7/8/2005 |
| Requesting advance approval of grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200527016(PDF, 12K) |
7/8/2005 |
| Issue: Railroad Retirement Tax Act Status. |
| 200527015(PDF, 24K) |
7/8/2005 |
| 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 to file an election under § 1.1502-21T(b)(3)(i) of the Income Tax Regulations to relinquish the entire carryback period for the consolidated net operating loss of a consolidated group. |
| 200527014(PDF, 40K) |
7/8/2005 |
| Requesting a ruling that a guarantee of bonds backed by a fund pursuant to a certain program will not cause the amounts in the fund to be treated as replacement proceeds of the bonds. |
| 200527013(PDF, 13K) |
7/8/2005 |
| Requesting a ruling that the rental income to be received by a company from a property under a lease is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200527012(PDF, 19K) |
7/8/2005 |
| Requesting rulings on behalf of Taxpayer concerning the Federal income tax treatment of long-term disability benefits paid through a long-term disability insurance program. |
| 200527011(PDF, 13K) |
7/8/2005 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election to be classified as an entity disregarded from its owner for federal tax purposes. |
| 200527010(PDF, 13K) |
7/8/2005 |
| Requesting an extension of time for a company to elect under § 301.7701- 3(c) of the Procedure and Administration Regulations to be treated as a disregarded entity. |
| 200527009(PDF, 49K) |
7/8/2005 |
| Requesting a ruling that amounts, if any, in a state’s General Fund, Special Fund and Budget Account, will not result in “other replacement proceeds” of bonds within the meaning of § 1.148-1(c)(4). |
| 200527008(PDF, 39K) |
7/8/2005 |
| Requesting a ruling concerning the generation-skipping transfer tax consequences of the proposed reformation of a GST Exempt Trust and the Non-Exempt Trust. |
| 200527007(PDF, 40K) |
7/8/2005 |
| Requesting certain rulings concerning a generation-skipping transfer and § 1433. |
| 200527006(PDF, 75K) |
7/8/2005 |
| Requesting rulings under section 29 of the Internal Revenue Code. |
| 200527005(PDF, 75K) |
7/8/2005 |
| Requesting rulings under section 29 of the Internal Revenue Code. |
| 200527004(PDF, 23K) |
7/8/2005 |
| Requesting a supplement of a prior letter ruling dated May 24, 2001 (PLR-127310-00). |
| 200527003(PDF, 17K) |
7/8/2005 |
| Requesting a ruling regarding the late filing of a Form 8716, Election To Have a Tax Year Other Than a Required Tax Year. |
| 200527002(PDF, 14K) |
7/8/2005 |
| Requesting a ruling concerning inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200527001(PDF, 18K) |
7/8/2005 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200526025(PDF, 382K) |
7/1/2005 |
| Requesting a ruling concerning the applicability of section 415(m) of the Internal Revenue Code to a county Excess Benefit Savings Plan and the tax consequences related therto. |
| 200526024(PDF, 198K) |
7/1/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3)(A) of the Internal Revenue Code. |
| 200526023(PDF, 268K) |
7/1/2005 |
| Requesting rulings under sections 401(a)(9) and 408(d)(3) of the Internal Revenue Code. |
| 200526022(PDF, 300K) |
7/1/2005 |
| Requesting rulings under section 404(a)(6) of the Internal Revenue Code. |
| 200526021(PDF, 36K) |
7/1/2005 |
| Requesting a ruling under section 4943 of the Internal Revenue Code. |
| 200526020(PDF, 21K) |
7/1/2005 |
| Requesting a ruling under section 83 of the Internal Revenue Code that the private placement of certain warrants by a company will not cause options issued to the company’s employees under a plan to be viewed as actively traded on an established market within the meaning of section 1.83-7(b)(1) of the Income Tax Regulations. |
| 200526019(PDF, 38K) |
7/1/2005 |
| Issue: Whether the tangible personal property, other tangible property, and non-residential real property used in connection with racetrack operations is includible in MACRS Asset Guideline Class 80.0, “Theme and Amusement Parks” (class 80.0) as described in Rev. Proc. 87-56, 1987-2 C.B. 674, for depreciation purposes. The particular emphasis of this issue is whether specialized land improvements are depreciated under class 80.0 or as land improvements described in asset guideline class 00.3 and as nonresidential real property. |
| 200526018(PDF, 57K) |
7/1/2005 |
| Issues: (1) Are payments to X Workers subject to employment taxes? (2) What reporting requirements apply to payments made to X Workers? (3) Are Project A employers eligible for relief under Section 530 of the Revenue Act of 1978 (section 530)? |
| 200526017(PDF, 23K) |
7/1/2005 |
| Requesting an extension of time under § 301.9100-1 of the Procedure and Administrative Regulations to make a qualified terminable interest property election under § 2056(b)(7) of the Internal Revenue Code. |
| 200526016(PDF, 16K) |
7/1/2005 |
| Requesting a ruling under § 41 of the Internal Revenue Code. |
| 200526015(PDF, 21K) |
7/1/2005 |
| Requesting an extension of time under Treas. Reg. § 301.9100-3 to file the statements described in § 1.1503-2(g)(2) |
| 200526014(PDF, 22K) |
7/1/2005 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200526013(PDF, 32K) |
7/1/2005 |
| Requesting relief from an inadvertent invalid under §1362(f) of the Internal Revenue Code to file an election to be treated as an S corporation. |
| 200526012(PDF, 12K) |
7/1/2005 |
| Requesting rulings under sections 521 and 1381(a) of the Internal Revenue Code. |
| 200526011(PDF, 30K) |
7/1/2005 |
| Requesting a ruling that for purposes of determining qualification as a regulated investment company under section 851(b)(3) of the Internal Revenue Code of 1986, that a fund should treat a particular sub-fund of a state’s Highway Fund, known as the “Infrastructure Fund,” as the “issuer” of certain special obligation bonds. |
| 200526010(PDF, 22K) |
7/1/2005 |
| Requesting rulings under §§ 642 and 691 of the Internal Revenue Code. |
| 200526009(PDF, 15K) |
7/1/2005 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200526008(PDF, 36K) |
7/1/2005 |
| Requesting a ruling letter on two issues involving Plan X posing the following two questions: 1. Whether Plan X is a retirement system within the meaning of Internal Revenue Code (Code) section 3121(b)(7)(F)? 2. Whether the services Plan X participants perform for Employer M will be considered employment for Federal Insurance Contributions Act (FICA) purposes? |
| 200526007(PDF, 15K) |
7/1/2005 |
| Requesting a written determination granting relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200526006(PDF, 23K) |
7/1/2005 |
| Requesting seeking inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200526005(PDF, 23K) |
7/1/2005 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200526004(PDF, 15K) |
7/1/2005 |
| Requesting permission for a corporation to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200526003(PDF, 15K) |
7/1/2005 |
| Requesting a written determination granting relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200526002(PDF, 30K) |
7/1/2005 |
| Issue: Whether the portion of a taxpayer’s apartment used by the taxpayer for a home office should be depreciated as residential rental property or nonresidential real property, if the taxpayer owns the apartment building in which the apartment is located and 80 percent or more of the gross rental income from the building is from dwelling units? |
| 200526001(PDF, 48K) |
7/1/2005 |
| Issues: (1) Whether an “Affidavit of Composite Return” (“composite return”) qualifies as a frivolous income tax return subject to penalty under section 6702? (2) Whether, based on the filing of a composite return, the IRS should assess the frivolous income tax return penalty under section 6702 against the taxpayer, income tax return preparer, or both? (3) Whether a composite return satisfies the requirements for a valid return? (4) What procedures should the IRS follow when receiving a composite return? (5) Would the IRS have enough facts to justify referring an income tax return preparer who prepares a composite return for a civil injunction investigation? |
| 200525020(PDF, 25K) |
6/24/2005 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200525019(PDF, 270K) |
6/24/2005 |
| Requesting relief under section 301.9100-3 of the Procedure and Administration Regulations. |
| 200525018(PDF, 968K) |
6/24/2005 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200525017(PDF, 19K) |
6/24/2005 |
| Requesting that a proposed set-aside be treated as a qualifying distribution within the meaning of section 4942(g)(2) of the Internal Revenue Code. |
| 200525016(PDF, 21K) |
6/24/2005 |
| Requesting approval of a set-aside under the suitability test of section 4942(g)(2)(B)(i) of the Internal Revenue Code and section 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations. |
| 200525015(PDF, 20K) |
6/24/2005 |
| Requesting approval of a set-aside of funds under section 4942(g)(2) of the Internal Revenue Code. |
| 200525014(PDF, 28K) |
6/24/2005 |
| Requesting a ruling on the proper treatment of the termination of X and whether the termination constitutes an act of self-dealing under Section 4941 of the Internal Revenue Code. |
| 200525013(PDF, 53K) |
6/24/2005 |
| Requesting rulings concerning issues related to leases of space by joint venture partnerships in which a taxable REIT subsidiary of a trust is a member; whether the rental of shopping carts at the trust’s properties will be treated as personal property that is leased in connection with the lease of real property within the meaning of section 856(d)(1)(C) of the Internal Revenue Code; and whether a partnership in which the trust is indirectly a member will realize gross income under section 856(c)(2) from reimbursements for certain expenses shared by the trust and other entities related to the trust. |
| 200525012(PDF, 20K) |
6/24/2005 |
| Requesting a ruling on the federal income tax consequences of a Model Deferred Compensation Plan in which an Entity X, represented to be a State S public instrumentality described in section 457(e)(1)(A), intends to be an eligible deferred compensation plan under section 457 of the Internal Revenue Code of 1986, as well as a trust which X has established, pursuant to a trust agreement, to hold the assets of the plan. |
| 200525011(PDF, 17K) |
6/24/2005 |
| 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. |
| 200525010(PDF, 37K) |
6/24/2005 |
| Requesting rulings that: 1. The investment by the Taxpayer in certificates of deposit or securitized b receivables issued by an industrial loan corporation will not disqualify the Taxpayer as a cooperative under section 1381(a) (2) of the Code. 2. The investment by the Taxpayer as an equity investor in an industrial loan corporation or holding company will not disqualify the Taxpayer as a cooperative under section 1381(a) (2) of the Code. 3. The interest earned by the Taxpayer on the certificates of deposits or securitized b receivables will be patronage sourced income. |
| 200525009(PDF, 16K) |
6/24/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200525008(PDF, 62K) |
6/24/2005 |
| Requesting rulings regarding the tax consequences of a proposed division of a charitable remainder unitrust. |
| 200525007(PDF, 26K) |
6/24/2005 |
| Requesting a waiver under § 7702(f)(8) of the Internal Revenue Code for contracts that failed to meet the requirements of § 7702(a). |
| 200525006(PDF, 17K) |
6/24/2005 |
| Requesting an extension of time, pursuant to § 301.9100-3 of the Procedure and Administration Regulations, to file a late Form 8832, Entity Classification Election. |
| 200525005(PDF, 14K) |
6/24/2005 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200525004(PDF, 31K) |
6/24/2005 |
| Requesting rulings that certain contracts proposed to be issued by Taxpayer will qualify as insurance contracts for federal income tax purposes. |
| 200525003(PDF, 40K) |
6/24/2005 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer tax consequences of severing a trust. |
| 200525002(PDF, 37K) |
6/24/2005 |
| Requesting rulings concerning an article (about limitation on benefits) of the United States-Country X income tax treaty. |
| 200525001(PDF, 19K) |
6/24/2005 |
| Requesting a ruling on the term to be used to allocate debt issuance costs for purposes of § 1.446-5 of the Income Tax Regulations in the case of callable debt that bears interest at a step rate. |
