| 200444046(PDF, 464K) |
8/2/2004 |
| Request for a letter ruling concerning church plans within the meaning of section 414(e) of the Internal Revenue Code. |
| 200444045(PDF, 278K) |
8/3/2004 |
| Request for a letter ruling concerning sections 401(a) and 402 of the Internal Revenue Code. |
| 200444044(PDF, 243K) |
7/30/2004 |
| Request for a letter ruling concerning sections 501(c)(3), 511 - 513 and more specifically 512(b)(1) and 512(b)(13) of the Internal Revenue Code. |
| 200444043(PDF, 60K) |
4/21/2004 |
| Rquest with respect to a defined benefit pension plan pursuant to Rev. Proc. 90-49. |
| 200444042(PDF, 186K) |
8/5/2004 |
| Request for a ruling under section 4943 of the Internal Revenue Code. |
| 200444041(PDF, 109K) |
8/2/2004 |
| Request for a set-aside to meet contingent liabilities and a court order as allowable under section 53.4242(a)-3(b)(9) of the Foundation and Similar Excise Taxes Regulations. |
| 200444040(PDF, 186K) |
8/3/2004 |
| Letter concerning conditional approval to extend amortization periods for unfunded liabilities ( described in section 412(b)(2)(B) of the Internal Revenue Code and section 302(b)(2)(B) of the Employee Retirement Income Security Act of 1974 ). |
| 200444039(PDF, 122K) |
8/4/2004 |
| Request for a approval of grant procedures under section 4945(g) of the Internal Revenue Code to be administered and supervised by a party exempt from Frederal income tax under section 501(c)(3) of the Code and classified as other than a private foundation under sections 509(a)(1) and 170(b)(1)(A)(vi). |
| 200444038(PDF, 201K) |
8/4/2004 |
| Request for advance approval of grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200444037(PDF, 146K) |
8/4/2004 |
| Request for advance approval of grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200444036(PDF, 379K) |
8/6/2004 |
| Request for ruling concerning approval of a proposed set-aside of funds to be treated as qualifying distributions under section 4942(g)(2) of the Internal Revenue Code. |
| 200444035(PDF, 208K) |
8/4/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200444034(PDF, 386K) |
8/3/2004 |
| Request for a letter ruling under section 408(d)(3) of the Internal Revenue Code. |
| 200444033(PDF, 385K) |
8/3/2004 |
| Request for a letter ruling under section 408(d)(3) of the Internal Revenue Code. |
| 200444032(PDF, 279K) |
8/5/2004 |
| Request for a letter ruling under section 403(b)(8) of the Internal Revenue Code. |
| 200444031(PDF, 189K) |
8/5/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200444030(PDF, 471K) |
8/5/2004 |
| Request for ruling concerning tax effects of a proposed transaction under sections 501(c)(3), 509(a)(1) and 511 through 514 of the Internal Revenue Code. |
| 200444029(PDF, 241K) |
8/5/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200444028(PDF, 215K) |
8/5/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200444027(PDF, 218K) |
8/5/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200444026(PDF, 50K) |
9/22/2004 |
| Issues: (1) Is interest collected through a state enforcement agency on past-due child support excludible from gross income under I.R.C. � 71(c) as part of the sum payable for the support of children of the payor spouse. (2) Whether any reporting obligation arises with regard to interest paid on past-due child support through a State enforcement agency. |
| 200444025(PDF, 39K) |
9/23/2004 |
| Issues: (1) Whether the IRS can use deficiency procedures to recover an erroneous refund made as a result of an inappropriately claimed foreign earned income exclusion. (2) Whether the unlimited statute of limitations under section 6501(c)(1) applies per se to these returns. |
| 200444023(PDF, 57K) |
7/12/2004 |
| Issues: (1) Whether, under section 2056(b)(5) or section 2056(b)(7) of the Internal Revenue Code, the surviving spouse�s interest in Trust 1 qualifies for the marital deduction. (2) Whether, under section 2056(b)(7), the surviving spouse�s interest in Trust 2 qualifies for the marital deduction. |
| 200444022(PDF, 172K) |
7/12/2004 |
| Issue: (1) Whether, pursuant to Treas. Reg. � 1.482-7(g), ForSub is required to make buyin payments to USCorp for intangible property made available by USCorp for purposes of research under a qualified cost sharing arrangement (�QCSA�). (2) Whether certain payments made by (or owed from) ForSub to USCorp may constitute foreign trading gross receipts (�FTGR�) under section 924(a)(2) or 942(a)(1)(B). (3) Whether ForSub sales of software products that incorporate USCorp intellectual property are included in the sales ratio used to apportion research and experimental (�R&E�) expenditures pursuant to Treas. Reg. � 1.861-17(c)(3) for purposes of computing taxable income under section 925(a)(2) of the foreign sales corporation (�FSC�) provisions, section 941(b)(1) of the extraterritorial income (�ETI�) exclusion provisions, or any other statutory or residual grouping of income. |
| 200444021(PDF, 37K) |
6/21/2004 |
| Issue: Whether the deduction for Amount 4 claimed on the Decedent�s estate tax return and representing income taxes paid by the estate on the estate�s income tax return with respect to distributions to the estate from individual retirement accounts (IRAs), should be allowed under � 2053(a) of the Internal Revenue Code. |
| 200444020(PDF, 32K) |
7/12/2004 |
| Issues: (1) The taxpayer makes a deposit in the nature of a cash bond for a particular tax year in anticipation of a deficiency to be determined. The Service later assesses a deficiency, plus interest, that is less than the cash bond deposit. At the taxpayer�s request, the remaining amount of the cash bond is moved to another taxable year. Does the remaining amount of the cash bond retain the original remittance date in the new taxable year in which it is placed? (2) Does the answer to Issue 1 change if the cash bond deposit date is a date earlier than the filing date (either unextended due date or actual filing date) of the return for the tax year to which the taxpayer has requested that the remaining amount of the cash bond be moved? (3) The taxpayer makes a deposit in the nature of a cash bond for a particular tax year in anticipation of a deficiency to be determined. The Service later assesses a deficiency, plus interest. The Service converts some or all of the cash bond into a payment of tax and applies it to the deficiency, plus interest. The taxpayer subsequently litigates issues (some or all of which produced some or all of the deficiency determined). The taxpayer prevails with regard to some of the original deficiency such that a refund of tax and deficiency interest is required. Can the refund regain its status as a cash bond? If the answer is yes, does the amount of that refund regain its original remittance date? |
| 200444019(PDF, 36K) |
6/24/2004 |
| Issue: Whether a hand-delivered Letter 569 (DO)(Claim Disallowance Letter) commences the two-year period of limitations within which to bring a refund suit in Federal Court under section 6532. |
| 200444018(PDF, 27K) |
7/12/2004 |
| Requesting a ruling under � 1362(f) of the Internal Revenue Code that the termination of Company's S corporation election was inadvertent. |
| 200444017(PDF, 27K) |
7/12/2004 |
| Requesting a ruling under � 1362(f) of the Internal Revenue Code that the termination of Company's S corporation election was inadvertent. |
| 200444016(PDF, 37K) |
7/9/2004 |
| Request for 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 exemptions to transfers made to certain trusts. |
| 200444015(PDF, 21K) |
7/14/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200444014(PDF, 32K) |
7/13/2004 |
| Requesting a ruling under � 1362(f) of the Internal Revenue Code. |
| 200444013(PDF, 32K) |
7/13/2004 |
| Requesting a ruling under � 1362(f) of the Internal Revenue Code. |
| 200444012(PDF, 32K) |
7/13/2004 |
| Requesting a ruling under � 1362(f) of the Internal Revenue Code. |
| 200444011(PDF, 22K) |
7/12/2004 |
| Requesting a ruling for 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 an association taxable as a corporation for federal tax purposes. |
| 200444010(PDF, 28K) |
7/15/2004 |
| 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. This request was made in accordance with � 301.9100-3. |
| 200444009(PDF, 34K) |
7/9/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of a generation-skipping transfer (GST) exemption. |
| 200444008(PDF, 17K) |
7/6/2004 |
| Requesting relief under � 1362(f) of the Internal Revenue Code. |
| 200444007(PDF, 29K) |
6/25/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200444006(PDF, 21K) |
7/1/2004 |
| Requesting an extension of time to elect to be treated as a partnership under � 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200444005(PDF, 21K) |
7/1/2004 |
| Requesting an extension of time to elect to be treated as a disregarded entity under � 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200444004(PDF, 53K) |
6/15/2004 |
| Request for several rulings concerning the organization of Trust and one or more other qualified settlement funds (QSFs) under section 468(g) of the Internal Revenue Code and sections 1.468B-1 through 1.468B-5 of the Income Tax Regulations, of a new corporation to operate a claims processing unit on a cooperative basis. Specifically, the letter requested the following rulings: (1) the new corporation will qualify as a corporation operating on a cooperative basis within the meaning of � 1381(a)(2); (2) assuming that Trust and the other members in the new cooperative otherwise qualify as QSFs under � 468(g) and �� 1.468B-1 through 1.468B-5, Trust�s membership in and receipt of patronage dividends from the new cooperative will not affect its status as a QSF; and (3) assuming that Trust and other members in the new cooperative otherwise qualify as QSFs under � 468(g) and �� 1.468B-1 through 1.468B-5, Trust�s transfer of certain assets to the new cooperative will not affect Trust�s status as a QSF. |
| 200444003(PDF, 27K) |
7/13/2004 |
| 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. |
| 200444002(PDF, 59K) |
7/22/2004 |
| A review of a debtor's bankruptcy plan. |
| 200444001(PDF, 68K) |
7/8/2004 |
| Issue: Whether assessments against TP, a forfeited corporation, are valid to use enforced collection against the assets of the TP. |
| 200443046(PDF, 199K) |
7/29/2004 |
| Request for a ruling to waive the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200443045(PDF, 579K) |
7/26/2004 |
| Request for a private letter ruling concerning whether a proposed transaction will affect X's tax exempt status under section 501(c)(3) and also cause excise taxes to be imposed under sections 4941-4945 of the Internal Revenue Code. |
| 200443044(PDF, 187K) |
7/26/2004 |
| Request for 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. |
| 200443043(PDF, 53K) |
7/26/2004 |
| Denied request for a waiver of the minimum funding standard. |
| 200443042(PDF, 140K) |
7/26/2004 |
| Request for waivers of the 10 percent excise tax due under section 4971(f)(1) of the Internal Revenue Code and the 100 percent excise tax due under section 4971(f)(2) of the Internal Revenue Code. |
| 200443041(PDF, 120K) |
7/27/2004 |
| Request for conditional waiver of the minimum funding standard under section 412(d) of the Internal Revenue Code. |
| 200443040(PDF, 236K) |
7/29/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200443039(PDF, 148K) |
7/29/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200443038(PDF, 164K) |
7/26/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200443037(PDF, 169K) |
7/27/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200443036(PDF, 193K) |
7/28/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200443035(PDF, 260K) |
7/28/2004 |
| Request for letter rulings under section 408(d)(3) of the Internal Revenue Code. |
| 200443034(PDF, 251K) |
7/29/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200443033(PDF, 14K) |
7/12/2004 |
| Final adverse ruling with respect to claim of exemption from federal income taxation under section 501(c)(3) of the Internal Revenue Code. |
| 200443032(PDF, 52K) |
7/13/2004 |
| Issue: Whether Taxpayer�s gain under � 311(b) of the Internal Revenue Code on the transfer of assets to newly-formed limited partnerships, followed by the pro rata distribution of the limited partnership interests to its shareholders, is determined as if Taxpayer sold the assets in their entirety for their fair market value, or by reference to the value of the individual limited partnership interests received by the shareholders? |
| 200443031(PDF, 83K) |
7/2/2004 |
| Requesting rulings under �� 29 and 702 of the Internal Revenue Code. |
| 200443030(PDF, 41K) |
7/7/2004 |
| Requesting a ruling that a disclaimer was a qualified disclaimer under section 2518 of the Internal Revenue Code. |
| 200443029(PDF, 57K) |
6/28/2004 |
| Requesting rulings concerning the lookthrough rule of � 1.817-5(f) of the Income Tax Regulations for satisfying the diversification requirements of � 817(h) of the Internal Revenue Code. |
| 200443028(PDF, 21K) |
6/30/2004 |
| Requesting a ruling on behalf of Corporation under � 1362(b)(5) of the Internal Revenue Code. |
| 200443027(PDF, 48K) |
7/7/2004 |
| Requesting rulings under �� 2044, 2056, 2519, 2652, and 2654 of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations. |
| 200443026(PDF, 22K) |
6/23/2004 |
| Requesting an extension of time pursuant to � 301.9100-3 of the Procedure PLR-159233-03 2 and Administration Regulations to make an election under � 754 of the Internal Revenue Code. |
| 200443025(PDF, 58K) |
6/28/2004 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations to make a reverse QTIP election under section 2652(a)(3) of the Internal Revenue Code with respect to the Exempt Marital Trust and to make an allocation of the generation-skipping transfer (GST) tax exemption to the Exempt Marital Trust under section 2642(g). |
| 200443024(PDF, 20K) |
6/30/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200443023(PDF, 67K) |
4/21/2004 |
| Requesting rulings regarding the income, gift and generation-skipping transfer (GST) tax consequences of a proposed judicial construction of a trust to permit proposed sales of remainder interests in the trust. |
| 200443022(PDF, 19K) |
7/13/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200443021(PDF, 19K) |
7/7/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200443020(PDF, 24K) |
6/29/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file a Form 8832, Entity Classification Election, electing under � 301.7701-3(c) to treat X as an association taxable as a corporation, and under � 1362(b)(5) of the Internal Revenue Code, to file a late Form 2553, electing to treat X as an S corporation. |
| 200443019(PDF, 34K) |
7/7/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Wife�s generation-skipping transfer (GST) exemption. |
| 200443018(PDF, 19K) |
6/22/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200443017(PDF, 22K) |
6/24/2004 |
| Requesting permission for Corporation to revoke its election under ' 41(c)(4) of the Internal Revenue Code. |
| 200443016(PDF, 91K) |
7/1/2004 |
| Requesting rulings under � 29 and � 702 of the Internal Revenue Code. |
| 200443015(PDF, 33K) |
7/9/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Wife�s generation-skipping transfer (GST) exemption. |
| 200443014(PDF, 19K) |
6/24/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200443013(PDF, 22K) |
7/13/2004 |
| 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. |
| 200443012(PDF, 29K) |
6/30/2004 |
| Requesting rulings under � 301.9100-3 of the Procedure and Administration Regulations and under � 1362(b)(5) of the Internal Revenue Code. |
| 200443011(PDF, 33K) |
7/9/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Husband�s generation-skipping transfer (GST) exemption. |
| 200443010(PDF, 34K) |
7/9/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Wife�s generationskipping transfer (GST) exemption. |
| 200443009(PDF, 29K) |
7/7/2004 |
| 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 the consolidated group of which Taxpayer is the common parent. |
| 200443008(PDF, 29K) |
7/7/2004 |
| 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 the consolidated group of which Taxpayer is the common parent. |
| 200443007(PDF, 34K) |
7/7/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Husband�s generation-skipping transfer (GST) exemption. |
| 200443006(PDF, 24K) |
6/29/2004 |
| Requesting a ruling on certain federal income tax consequences of a proposed transaction. Specifically, a ruling regarding the application of the successor asset rule under � 1.1502-13(j)(1) of the Income Tax Regulations (the �Regulations�) and the multiple trigger rule under � 1.1502-13(j)(3) of the Regulations. |
| 200443005(PDF, 53K) |
6/25/2004 |
| Request for a revised schedule of ruling amounts pursuant to � 1.468A-3(i) of the Income Tax Regulations. |
| 200443004(PDF, 53K) |
7/9/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to make a reverse qualified terminable interest property (QTIP) election under � 2652(a)(3) of the Internal Revenue Code with respect to a trust. |
| 200443003(PDF, 85K) |
7/1/2004 |
| Requesting a private letter ruling concerning the tax consequences of the sale of Plant and associated assets and liabilities, including nuclear decommissioning liability, between Seller 1, Seller 2, and Buyer. Specifically, you have requested rulings regarding the tax consequences under section 468A of the Internal Revenue Code to the Sellers' nuclear decommissioning funds and Buyer's nuclear decommissioning fund as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and associated assets. |
| 200443002(PDF, 85K) |
7/1/2004 |
| Requesting a private letter ruling concerning the tax consequences of the sale of Plant and associated assets and liabilities, including nuclear decommissioning liability, between Seller 1, Seller 2, and Buyer. Specifically, you have requested rulings regarding the tax consequences under section 468A of the Internal Revenue Code to the Sellers' nuclear decommissioning funds and Buyer's nuclear decommissioning fund as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and associated assets. |
| 200443001(PDF, 85K) |
7/1/2004 |
| Requesting a private letter ruling concerning the tax consequences of the sale of Plant and associated assets and liabilities, including nuclear decommissioning liability, between Seller 1, Seller 2, and Buyer. Specifically, you have requested rulings regarding the tax consequences under section 468A of the Internal Revenue Code to the Sellers' nuclear decommissioning funds and Buyer's nuclear decommissioning fund as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and associated assets. |
| 200442037(PDF, 70K) |
7/22/2004 |
| Request for rulings on the proper treatment under section 414(I) of the Internal Revenue Code of a spin-off of the defined contribution portion of the Code section 414(k) plan into a seperate plan. |
| 200442036(PDF, 46K) |
7/23/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200442035(PDF, 45K) |
7/23/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200442034(PDF, 41K) |
7/22/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200442033(PDF, 44K) |
7/9/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200442032(PDF, 41K) |
7/22/2004 |
| Request for a letter ruling regarding a distribution from "Plan X." |
| 200442031(PDF, 25K) |
6/25/2004 |
| Legal advice on (1) whether certain indemnity arrangements between n operating LLCs that are proposed to be formed and Captive are insurance contracts for federal tax purposes and on (2) whether Captive will be taxable as an insurance company other than life under � 831(a) of the Internal Revenue Code. |
| 200442030(PDF, 22K) |
6/22/2004 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations to make an election under section 754 of the Internal Revenue Code. |
| 200442029(PDF, 26K) |
7/1/2004 |
| Requesting a ruling under section 301.9100-3 of the Procedure and Administration Regulations and section 1362(b)(5) of the Internal Revenue Code. |
| 200442028(PDF, 23K) |
6/4/2004 |
| Requesting an extension of time to make an election under � 754 of the Internal Revenue Code. |
| 200442027(PDF, 35K) |
6/21/2004 |
| Requesting rulings on proposed disclaimers. |
| 200442026(PDF, 20K) |
7/2/2004 |
| Requesting permission to revoke its election under � 41(c)(4) of the Internal Revenue Code. |
| 200442025(PDF, 20K) |
7/1/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200442024(PDF, 38K) |
10/15/2004 |
| Request for ruling concerning the creation of a trust pursuant to a plan of reorganization under chapter 11 of the U.S. Bankruptcy Code established to satisfy certain asbestos-related personal injury claims. |
| 200442023(PDF, 35K) |
6/24/2004 |
| Request for a letter ruling that payments to certain individuals are not subject to information reporting under � 6041 of the Internal Revenue Code because the payments are excludable from the gross income of the recipients of the payments as gifts under � 102. |
| 200442022(PDF, 25K) |
6/25/2004 |
| Request for an extension of time under Treas. Reg. � 301.9100-3 to file the election and agreement described in �1.1503-2(g)(2)(i) as required by � 1.1503-2(g)(2)(iv)(B)(2)(iii). |
| 200442021(PDF, 27K) |
7/1/2004 |
| Issue: Whether, under the circumstances described below, Taxpayer is the proper claimant for purposes of �� 34, 6421, and 6427 of the Internal Revenue Code with respect to the tax imposed on gasoline and diesel fuel. |
| 200442020(PDF, 69K) |
4/21/2004 |
| Requesting rulings regarding the income, gift and generation-skipping transfer (GST) tax consequences of a proposed judicial construction of Trust to permit proposed sales of remainder interests in Trust. |
| 200442019(PDF, 69K) |
4/21/2004 |
| Requesting rulings regarding the income, gift and generation-skipping transfer (GST) tax consequences of a proposed judicial construction of Trust to permit proposed sales of remainder interests in Trust. |
| 200442018(PDF, 26K) |
6/28/2004 |
| Requesting an extension of time under section 301.9100-1 of the Procedure and Administration Regulations to make an election under section 856(l) of the Internal Revenue Code. |
| 200442017(PDF, 53K) |
6/25/2004 |
| Request for a revised schedule of ruling amounts pursuant to � 1.468A-3(i) of the Income Tax Regulations. |
| 200442016(PDF, 23K) |
6/28/2004 |
| Request, in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, to change an accounting period, for federal income tax purposes. Request that the Form 1128 be considered timely filed under the authority contained in section 301.9100-3 of the Procedure and Administration Regulations. |
| 200442015(PDF, 49K) |
6/25/2004 |
| Requesting a letter ruling concerning whether the transfer of an intertie from Generator to Taxpayer is a nonshareholder contribution to capital excludable from income under � 118(a) of the Internal Revenue Code. |
| 200442014(PDF, 50K) |
6/30/2004 |
| Requesting rulings under � 29 of the Internal Revenue Code. |
| 200442013(PDF, 32K) |
6/18/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of generationskipping transfer (GST) tax exemption. |
| 200442012(PDF, 34K) |
6/18/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of generationskipping transfer (GST) tax exemption. |
| 200442011(PDF, 54K) |
10/23/2003 |
| Requesting a private letter ruling concerning the application of various sections of the Internal Revenue Code to Taxpayer�s settlement of certain liabilities. |
| 200442010(PDF, 34K) |
6/29/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Taxpayer�s generation-skipping transfer (GST) exemption. |
| 200442009(PDF, 35K) |
6/29/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Taxpayer�s generation-skipping transfer (GST) exemption. |
| 200442008(PDF, 132K) |
6/22/2004 |
| Requesting a private letter ruling regarding a proposed transaction. |
| 200442007(PDF, 132K) |
6/22/2004 |
| Requesting a private letter ruling regarding a proposed transaction. |
| 200442006(PDF, 67K) |
6/29/2004 |
| Request for a private letter ruling on behalf of "Practice Plan." |
| 200442005(PDF, 26K) |
6/18/2004 |
| Requesting an extension of time pursuant to ' 301.9100-3 of the Procedure and Administration Regulations for Taxpayer to file an application for certification of historic status with the United States Department of Interior for purposes of � 47(a)(2) of the Internal Revenue Code. |
| 200442004(PDF, 25K) |
6/30/2004 |
| 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. |
| 200442003(PDF, 59K) |
6/22/2004 |
| Request for a ruling that X�s payment of a lump sum of money to Y in exchange for Y�s community property interest in a nonqualified deferred compensation plan payable to X by "Company" will constitute nontaxable transfers between former spouses that are related to the cessation of their marriage under section 1041 of the Internal Revenue Code, and that the �assignment of income doctrine� will not cause Y to be taxed when X receives payment of that deferred compensation from Company. You have also requested a ruling that the exchange is a transfer �for full and adequate consideration in money or money�s worth� under � 2516 of the Code that will not result in a taxable gift by either X or Y to the other. |
| 200442002(PDF, 28K) |
6/29/2004 |
| Requesting the consent of the Commissioner of Internal Revenue to revoke Taxpayer�s election not to deduct the 30-percent additional first year depreciation made on its B federal tax return for the taxable year ended A. |
| 200442001(PDF, 38K) |
6/3/2004 |
| Requesting rulings under section 117(d) of the Internal Revenue Code of 1986 (Code) regarding the proper federal income tax treatment of certain tuition reduction benefits provided a University under the University�s tuition assistance program. |
| 200441039(PDF, 130K) |
7/12/2004 |
| Requesting rulings under sections 61, 419, 419A, 501 and 4976 of the Internal Revenue Code regarding certain proposed transactions. |
| 200441038(PDF, 86K) |
7/14/2004 |
| Request for rulings related to restructuring of X, a very large organization described in sections 501(c)(3) and 509(a)(2) of the Internal Revenue Code. |
| 200441037(PDF, 79K) |
7/13/2004 |
| Request for rulings regarding transfer of assets pursuant to section 507(b)(2) of the Internal Revenue Code, similar to transfers discussed in Revenue Ruling 2002-28, 2002-1 C.B. 942. |
| 200441036(PDF, 33K) |
7/12/2004 |
| Request for ruling regarding an approval of a set-aside amount 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. |
| 200441035(PDF, 30K) |
7/14/2004 |
| Request for a waiver of the 60-day rollover requirement pursuant to section 402(c)(3)(B) of the Internal Revenue Code. |
| 200441034(PDF, 37K) |
7/15/2004 |
| Requesting advance approval of grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200441033(PDF, 56K) |
7/12/2004 |
| Request for a ruling under section 53.4941(d)-2(f)(2) of the Income Tax Regulations. |
| 200441032(PDF, 44K) |
7/15/2004 |
| Request for a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code ( the Code ), as applicable to an annuity described in the Code section 403(b) pursuant to the Code section 403(b)(8)(B). |
| 200441031(PDF, 33K) |
7/16/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200441030(PDF, 53K) |
8/20/2004 |
| Issues: (1) How should foreign source income be calculated for purposes of the foreign tax credit limitation when a self-employed taxpayer makes deductible contributions to a U.S. retirement plan? (2) How is a U.S. retirement plan distribution, derived (in whole or in part) from foreignsourced income, taxed? |
| 200441029(PDF, 75K) |
4/7/2004 |
| Request for technical assistance on FICA refund claim. |
| 200441028(PDF, 30K) |
8/30/2004 |
| Issue: Whether an individual who is a registered and licensed public accountant in Pennsylvania, but is not a CPA, is eligible to practice before the IRS by virtue of their public accountant�s license? |
| 200441027(PDF, 31K) |
5/3/2004 |
| Issue: Whether the taxpayer�s Form 1120X, Amended U.S. Corporation Income Tax Return, constitutes a processible return for purposes of I.R.C. � 6611(g) when the Internal Revenue Service (Service) received it on September 19, 2002. |
| 200441026(PDF, 80K) |
6/25/2004 |
| Issue: Whether the carryback of net operating losses (NOLs) arising in separate return years of P to consolidated return years of the Old P group is subject to the separate return year limitations of �1.1502-21A(c) or �1.1502-21T(c) (the �SRLY rules�), as applicable. |
| 200441025(PDF, 74K) |
6/14/2004 |
| Request for the following rulings: (1) That the proposed allocation of proceeds of the Bonds to the Parking Unit (defined below) is reasonable. (2) That certain contractual arrangements for the use of the Project (defined below) will not cause the Bonds to meet the private business tests under section 141(b) of the Internal Revenue Code. |
| 200441024(PDF, 37K) |
6/10/2004 |
| Requesting rulings concerning the termination of a trust. |
| 200441023(PDF, 28K) |
6/3/2004 |
| Requesting a ruling that split-dollar life insurance arrangements will not cause more than one class of stock within the meaning of section 1361(b)(1)(D) of the Internal Revenue Code. |
| 200441022(PDF, 44K) |
6/3/2004 |
| Requesting a ruling that the severance of Trust is a qualified severance under � 2642(a)(3) of the Internal Revenue Code (Code) and an extension of time under �� 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make a �reverse� qualified terminable interest property (�QTIP�) election under � 2652(a)(3). |
| 200441021(PDF, 32K) |
6/22/2004 |
| Request for a ruling that the use of bond proceeds in a parity reserve fund as described below to redeem certain bonds secured by the reserve will not cause the issues to which those proceeds are allocated to be refunding issues. |
| 200441020(PDF, 19K) |
6/15/2004 |
| Requesting an extension of time under Treas. Reg. � 301-9100-3 to elect the foreign earned income exclusion under section 911 of the Internal Revenue Code. |
| 200441019(PDF, 31K) |
6/21/2004 |
| Requesting rulings under �� 664 and 4941 of the Internal Revenue Code. |
| 200441018(PDF, 81K) |
6/17/2004 |
| Requesting rulings on the income and generation-skipping transfer (GST) tax consequences of the proposed reformation and partition of the Trust. |
| 200441017(PDF, 22K) |
6/15/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code that Company's presumptively late election under � 1362(a) to be an S corporation will be treated as timely made. |
| 200441016(PDF, 19K) |
6/21/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200441015(PDF, 43K) |
3/2/2004 |
| Requesting rulings under �� 61, 1001, and 1361(d)(3) of the Internal Revenue Code. |
| 200441014(PDF, 47K) |
3/2/2004 |
| Requesting rulings under �� 61, 1001, and 1361(d)(3) of the Internal Revenue Code. |
| 200441013(PDF, 56K) |
3/2/2004 |
| Requesting rulings under �� 61, 1001, 1361(d)(3), and 2601 of the Internal Revenue Code. |
| 200441012(PDF, 51K) |
6/10/2004 |
| Request for a revised schedule of ruling amounts pursuant to � 1.468A-3(i) of the Income Tax Regulations. |
| 200441011(PDF, 51K) |
6/10/2004 |
| Request for a revised schedule of ruling amounts pursuant to � 1.468A-3(i) of the Income Tax Regulations. |
| 200441010(PDF, 28K) |
6/15/2004 |
| Requesting relief under section 1362(f) of the Internal Revenue Code. |
| 200441009(PDF, 28K) |
6/21/2004 |
| Requesting a ruling under � 1362(f) regarding the inadvertent termination of X�s election to be an S corporation. |
| 200441008(PDF, 23K) |
4/6/2004 |
| Request for an extension of time under Treas. Reg. � 301.9100-3 to file an agreement described in Treas. Reg. � 1.1503-2(g)(2)(i) (�2(g)(2)(i) agreement�), and to file the annual certification described in � 1.1503-2(g)(2)(vi)(B). |
| 200441007(PDF, 29K) |
6/17/2004 |
| Requesting rulings on certain federal income tax consequences of stock redemptions made following a proposed change to the taxpayer�s Articles of Incorporation. |
| 200441006(PDF, 21K) |
6/22/2004 |
| Request for an extension of time under Treas. Reg. � 301.9100-3 to file an election and agreement described in Treas. Reg. � 1.1503-2(g)(2) |
| 200441005(PDF, 33K) |
5/26/2004 |
| Requesting a ruling concerning the generation-skipping transfer tax consequences of the proposed extension of Trust pursuant to section 2601 of the Internal Revenue Code. |
| 200441004(PDF, 27K) |
6/8/2004 |
| Requesting a ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200441003(PDF, 26K) |
6/8/2004 |
| Requesting a ruling that the rental income to be received by Company from the Property is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200441002(PDF, 44K) |
5/11/2004 |
| Issues: (1) When an income tax return reflecting an overpayment of tax is postmarked on the extended due date for filing the return, but the Service receives the return two days later, when does the section 6611(e)(1) 45-day interest-free period start? (2) Does IRM section 20.2.4.7.2.2 reflect the Service�s position in Revenue Ruling 74-236? (3) When is an overpayment �refunded� to a taxpayer for purposes of section 6611(e)(1) of the Code? |
| 200441001(PDF, 53K) |
6/8/2004 |
| Request for a revised schedule of ruling amounts in accordance with section 1.468A-3(i)(1) of the Income Tax Regulations. |
| Request for informal advice on whether attorneys' fees and administrative costs recovered in a class action lawsuit are includable in the gross incomes of the individual class members. |
| 200440031(PDF, 78K) |
7/6/2004 |
| Request for letter rulings under section 401(a)(9) of the Internal Revenue Code. |
| 200440030(PDF, 33K) |
7/8/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200440029(PDF, 22K) |
7/9/2004 |
| Request for a waiver of the 10 percent excise tax on the accumulated funding deficiency for the plan year and for waivers of the 100 percent excise tax on the accumulated funding deficiencies for the plan years. |
| 200440028(PDF, 55K) |
7/8/2004 |
| Request for a ruling with respect to the federal income treatment of certain contributions to a plan under section 414(h)(2) of the Internal Revenue Code. |
| 200440027(PDF, 33K) |
7/8/2004 |
| Request for a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200440026(PDF, 27K) |
7/6/2004 |
| Request for a waiver of the 60-day rollover requirement in section 402(c)(3) of the Internal Revenue Code. |
| 200440025(PDF, 44K) |
7/8/2004 |
| Request for a series of letter rulings under sections 401(a)(9) and 408(d)(3) of the Internal Revenue Code. |
| 200440024(PDF, 44K) |
7/7/2004 |
| Request for a series of letter rulings under section 408(d)(3) of the Internal Revenue Code. |
| 200440023(PDF, 35K) |
4/9/2004 |
| Issue: Is the taxpayer�s liability for an �estimated� monthly license fee, described below, fixed and incurred when paid under I.R.C. � 461? |
| 200440022(PDF, 22K) |
6/9/2004 |
| Requesting an extension of time under section 301.9100-3 of the Procedure and Administration Regulations to make an election under section 754 of the Internal Revenue Code. |
| 200440021(PDF, 21K) |
6/8/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200440020(PDF, 46K) |
6/4/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer (GST) Tax exemption. |
| 200440019(PDF, 45K) |
6/4/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer (GST) Tax exemption. |
| 200440018(PDF, 48K) |
6/15/2004 |
| Requesting an extension of time to file joint elections for each entity to be treated as a taxable REIT subsidiary under section 856(l) of the Internal Revenue Code. |
| 200440017(PDF, 18K) |
6/7/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200440016(PDF, 27K) |
6/1/2004 |
| Request for an extension of time under � 301.9100-1 of the Procedure and Administration Regulations to file an amended Form 8328 (Carryforward Election of Unused Private Activity Bond Volume Cap) for Authority to make a carryforward election under � 146(f) of the Internal Revenue Code. |
| 200440015(PDF, 21K) |
6/7/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200440014(PDF, 24K) |
5/21/2004 |
| 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. |
| 200440013(PDF, 22K) |
5/21/2004 |
| 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. |
| 200440012(PDF, 32K) |
5/17/2004 |
| Request for a ruling that gains from options on gold and futures contracts on gold that are entered into to reduce the risks of holding long positions in gold-related securities constitute other income (including but not limited to gains from options, futures, or forward contracts) derived with respect to its business of investing in stock, securities, or currencies within the meaning of section 851(b)(2) of the Internal Revenue Code of 1986. |
| 200440011(PDF, 58K) |
6/4/2004 |
| Request for a revised schedule of ruling amounts in accordance with section 1.468A-3(i)(1) of the Income Tax Regulations. |
| 200440010(PDF, 23K) |
6/7/2004 |
| Requesting a ruling for 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. |
| 200440009(PDF, 40K) |
6/14/2004 |
| Requesting a private letter ruling that the proposed merger of a wholly owned domestic subsidiary of a foreign corporation with and into a domestic corporation will qualify for an exception to the general rule of section 367(a)(1) of the Internal Revenue Code of 1986. |
| 200440008(PDF, 22K) |
6/10/2004 |
| Request asking 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. |
| 200440007(PDF, 25K) |
6/8/2004 |
| Requesting a ruling that the rental income received is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200440006(PDF, 24K) |
6/9/2004 |
| 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. |
| 200440005(PDF, 46K) |
6/10/2004 |
| Requesting a ruling that (1) the delivery of borrowed shares in satisfaction of the Financial Contracts will not cause the subsidiary to recognize gain on the Financial Contracts; (2) the delivery of borrowed shares does not give rise to constructive sales of the Financial Contracts under Section 1259(c)(1)(D); and (3) the delivery of borrowed shares and the retention of the Existing shares results in gain recognition under section 1259(c)(1)(A) equal to the excess of the fair market value of the Existing Shares over the subsidiary�s basis in the Existing Shares. |
| 200440004(PDF, 24K) |
6/7/2004 |
| Requesting a ruling on certain federal income tax consequences of a proposed transaction. |
| 200440003(PDF, 24K) |
6/7/2004 |
| Requesting a ruling on certain federal income tax consequences of a proposed transaction. |
| 200440002(PDF, 42K) |
6/14/2004 |
| Request for a private letter ruling regarding � 1031 of the Internal Revenue Code. |
| 200440001(PDF, 28K) |
6/9/2004 |
| Requesting a private letter ruling under � 45 of the Internal Revenue Code. |
