| 200453027(PDF, 185K) |
10/4/2004 |
| Requesting a waiver of the 60-day rollover period requirement found in Section 408(d)(3)(A) of the Internal Revenue Code. |
| 200453026(PDF, 212K) |
10/4/2004 |
| Requesting a ruling concerning the required minimum distribution rule under section 401(a)(9) of the Income Tax Code. |
| 200453025(PDF, 133K) |
10/5/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200453024(PDF, 172K) |
10/4/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200453023(PDF, 545K) |
10/4/2004 |
| Requesting a ruling under section 401(a)(9) of the Intemal Revenue Code. |
| 200453022(PDF, 177K) |
10/4/2004 |
| Requesting a waiver of the 60-day rollover period requirement found in Section 402(c)(3)(B) of the Internal Revenue Code. |
| 200453021(PDF, 151K) |
10/7/2004 |
| Requesting a waiver of the 60-day rollover period requirement found in Section 402(c)(3) of the Internal Revenue Code. |
| 200453020(PDF, 163K) |
10/7/2004 |
| Requesting a waiver of the 60-day rollover period requirement found in Section 402(c)(3)(B) of the Internal Revenue Code. |
| 200453019(PDF, 245K) |
9/30/2004 |
| Requesting a waiver of the 60-day rollover period requirement found in Section 408(d)(3) of the Internal Revenue Code. |
| 200453018(PDF, 326K) |
10/6/2004 |
| Requesting a waiver of the 60-day rollover period requirement found in Section 408(d)(3) of the Internal Revenue Code. |
| 200453017(PDF, 232K) |
10/6/2004 |
| Requesting relief under section 301.9100-3 of the Procedure and Administration Regulations. |
| 200453016(PDF, 236K) |
10/6/2004 |
| Requesting a waiver of the 60-day rollover period requirement found in Section 408(d)(3) of the Internal Revenue Code. |
| 200453015(PDF, 208K) |
10/4/2004 |
| Requesting a ruling concerning the minimum distribution rule under section 401(a)(9) of the Income Tax Code. |
| 200453014(PDF, 76K) |
8/13/2004 |
| Issues: (1) Does Taxpayer qualify for taxation under �833 of the Internal Revenue Code as an existing Blue Cross or Blue Shield organization for taxable years after it lost its Organization license, without regard to any changes in operations or structure? (2) Does Taxpayer�s loss of its Organization license constitute a material change in operations or in structure? |
| 200453013(PDF, 123K) |
10/6/2004 |
| Issues: (1) Were Taxpayer 3 a domestic corporation, would it have qualified as an insurance company under part II of subchapter L for the year involved? (2) Was Taxpayer 3 eligible to elect under � 953(d) to be treated as a domestic corporation? If not, how is the income of Taxpayer 3 accounted for under subpart F and other provisions that apply to foreign corporations? (3) Are the arrangements at issue a sham for federal income tax purposes? |
| 200453012(PDF, 130K) |
12/31/2004 |
| Issues: (1) Were Taxpayer 3 a domestic corporation, would it have qualified as an insurance company under part II of subchapter L for the year involved? (2) Was Taxpayer 3 eligible to elect under � 953(d) to be treated as a domestic corporation? If not, how is the income of Taxpayer 3 accounted for under subpart F and other provisions that apply to foreign corporations? (3) Are the arrangements at issue a sham for federal income tax purposes? |
| 200453011(PDF, 53K) |
9/14/2004 |
| Requesting rulings on the income, gift, and generation-skipping transfer tax consequences of a proposed merger of two trusts. |
| 200453010(PDF, 53K) |
9/14/2004 |
| Requesting rulings on the income, gift, and generation-skipping transfer tax consequences of a proposed merger of two trusts. |
| 200453009(PDF, 38K) |
9/24/2004 |
| Issue: Whether Taxpayer�s income is exempted from federal income taxation by section 115 of the Internal Revenue Code. |
| 200453008(PDF, 15K) |
9/27/2004 |
| Letter relating to the Private Letter Ruling, Project number INTL- 729-89 dated January 18, 1990 and section 897 of the Internal Revenue Code to the liquidating distributions. |
| 200453007(PDF, 33K) |
8/13/2004 |
| Requesting a ruling under � 1362(a) of the Internal Revenue Code. |
| 200453006(PDF, 30K) |
8/16/2004 |
| Requesting relief pursuant to � 1362(f) of the Internal Revenue Code. |
| 200453005(PDF, 25K) |
9/13/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election to be classified as an entity disregarded from an owner for federal tax purposes. |
| 200453004(PDF, 30K) |
9/20/2004 |
| 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 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 of the consolidated group. |
| 200453003(PDF, 91K) |
9/15/2004 |
| Issues: Whether the proposed transaction: (i) satisfies the business purpose requirement of � 1.355-2(b) of the Income Tax Regulations, (ii) is used principally as a device for the distribution of the earnings and profits of the distributing corporation or the controlled corporation or both (see � 355(a)(1)(B) of the Internal Revenue Code and � 1.355-2(d)), or (iii) is part of a plan (or series of related transactions) pursuant to which one or more persons will acquire directly or indirectly stock representing a 50-percent or greater interest in the distributing corporation or the controlled corporation (see � 355(e)(2)(A)(ii) and � 1.355-7T). |
| 200453002(PDF, 76K) |
8/31/2004 |
| Issues: (1) Use by Utility 2 and Utility 3 of the Generator Components (defined below) pursuant to the Project will not be private business use of the proceeds of the Bonds. (2) The Service Provider�s use of the Generator Components pursuant to the Contracts (defined below) will not be private business use of the proceeds of the Bonds. |
| 200453001(PDF, 56K) |
9/22/2004 |
| Requesting a ruling under � 166 of the Internal Revenue Code. |
| 200452054(PDF, 357K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452053(PDF, 351K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452052(PDF, 354K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452051(PDF, 402K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452050(PDF, 348K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452049(PDF, 414K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452048(PDF, 363K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452047(PDF, 238K) |
10/1/2004 |
| Requesting a waiver of the 60-day rollover period requirement found in Section 408(d)(3)(A) of the Internal Rvenue Code with respect to a distribution received from an individual retirement annuity. |
| 200452046(PDF, 367K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452045(PDF, 414K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452044(PDF, 370K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452043(PDF, 510K) |
9/28/2004 |
| Requesting a ruling concerning the status of a contribution to an individual retirement account. |
| 200452042(PDF, 242K) |
9/30/2004 |
| Requesting a waiver of the 60-day rollover period requirement found in Section 408(d)(3) of the Internal Rvenue Code. |
| 200452041(PDF, 339K) |
9/30/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200452040(PDF, 192K) |
9/30/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200452039(PDF, 304K) |
9/30/2004 |
| Requesting rulings concerning the limitations on benefits under section 415 of the Internal Revenue Code. |
| 200452038(PDF, 183K) |
10/1/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200452037(PDF, 55K) |
11/22/2004 |
| Issue: Whether the section 4945 first tier excise tax imposed on X for its failure to include the required expenditure responsibility reports on its Form 990-PF for fiscal year ended should be abated as provided in section 4962(a) of the Code. |
| 200452036(PDF, 186K) |
9/29/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200452035(PDF, 62K) |
10/1/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200452034(PDF, 40K) |
10/1/2004 |
| Issue: Whether spent fuel rods are solid waste within the meaning of � 142(a)(6) of the Internal Revenue Code of 1986 (the 1986 Code). |
| 200452033(PDF, 27K) |
9/27/2004 |
| Issue: To what extent does � 1234A of the Internal Revenue Code apply to amounts received by a taxpayer upon its surrender or termination of whole life insurance contracts? |
| 200452032(PDF, 22K) |
9/28/2004 |
| Issues: (1) Is the gross QREs method a �reasonable� method of allocating the group credit for purposes of � 41(f) of the Internal Revenue Code? (2) If so, for taxable years ending before December 29, 1999, may a taxpayer that is a member of a controlled group use the gross QREs method to allocate the group credit even though the other member of the controlled group uses a different method, and the controlled group as a whole claims more than 100 percent of the group credit? |
| 200452031(PDF, 21K) |
8/31/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200452030(PDF, 25K) |
9/13/2004 |
| Requesting an extension of time under � 301.9100 of the Procedure and Administration Regulations to make an alternate valuation election under � 2032 of the Internal Revenue Code. |
| 200452029(PDF, 46K) |
9/13/2004 |
| Requesting an extension of time pursuant to � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to allocate generation-skipping transfer (GST) tax exemption to transfers made to a trust. |
| 200452028(PDF, 28K) |
9/13/2004 |
| Requesting an extension of time under � 301.9100-1(c) of the Procedure and Administration Regulations to file the required Forms 970, Applications to use LIFO Inventory Method. This request is made in accordance with � 301.9100-3. |
| 200452027(PDF, 51K) |
12/24/2004 |
| Requesting a ruling concerning participation in a hospital�s student loan program for nurses. |
| 200452026(PDF, 40K) |
9/13/2004 |
| Issues: (1) The Taxpayer is a qualified settlement fund under � 1.468B-1. (2) The Taxpayer was a qualified settlement fund when the county transferred cash to it. (3) The Taxpayer may exclude from its modified gross income interest earned on the seized cash while it was in the custody of the county. |
| 200452025(PDF, 21K) |
9/9/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200452024(PDF, 23K) |
9/14/2004 |
| Requesting relief under � 1362(f) of the Internal Revenue Code. |
| 200452023(PDF, 24K) |
9/14/2004 |
| Requesting an extension of time under � 301.9100-1(c) of the Procedure and Administration Regulations to elect to be treated as a qualified subchapter S subsidiary (QSub) for federal tax purposes. |
| 200452022(PDF, 24K) |
9/14/2004 |
| Requesting an extension of time under � 301.9100-1(c) of the Procedure and Administration Regulations to elect to be treated as a qualified subchapter S subsidiary (QSub) for federal tax purposes. |
| 200452021(PDF, 24K) |
9/14/2004 |
| Requesting an extension of time under � 301.9100-1(c) of the Procedure and Administration Regulations to elect to be treated as a qualified subchapter S subsidiary (QSub) for federal tax purposes. |
| 200452020(PDF, 18K) |
9/14/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200452019(PDF, 22K) |
9/10/2004 |
| Requesting permission to change an accounting period under the Form 1128 and be considered timely filed under the authority contained in � 301.9100-3 of the Procedure and Administration Regulations. |
| 200452018(PDF, 19K) |
8/31/2004 |
| Requesting permission to change an accounting period under the Form 3115 and be considered timely filed under the authority contained in � 301.9100-3 of the Procedure and Administration Regulations. |
| 200452017(PDF, 23K) |
9/14/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200452016(PDF, 27K) |
12/24/2004 |
| Requesting an extension of time under section 301.9100-1(c) of the Procedure and Administration Regulations to file the required Form 970, Application to use the LIFO Inventory Method. This request was made in accordance with section 301.9100-3. |
| 200452015(PDF, 21K) |
9/14/2004 |
| Requesting a ruling under � 301.9100-3(a) of the Procedure and Administration Regulations for an extension of time to file an election for LLC to be treated as an association for federal tax purposes. |
| 200452014(PDF, 22K) |
9/10/2004 |
| 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 Internal Revenue Code. |
| 200452013(PDF, 34K) |
9/14/2004 |
| Requesting rulings concerning the proper Federal tax treatment of a medical reimbursement plan. |
| 200452012(PDF, 30K) |
9/14/2004 |
| Requesting an extension of time under Treas. Reg. � 301.9100-3 to file the annual certifications described in �1.1503-2(g)(2)(vi)(B). |
| 200452011(PDF, 27K) |
8/31/2004 |
| Requesting relief under section 1362(f) of the Internal Revenue Code. |
| 200452010(PDF, 41K) |
9/13/2004 |
| Requesting rulings regarding an estate�s right of recovery under � 2207A of the Internal Revenue Code. |
| 200452009(PDF, 26K) |
8/31/2004 |
| Requesting relief under section 1362(f) of the Internal Revenue Code. |
| 200452008(PDF, 24K) |
9/14/2004 |
| 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 Internal Revenue Code. |
| 200452007(PDF, 30K) |
9/14/2004 |
| Requesting under � 301.9100-3 of the Procedure and Administration Regulations an extension of time to elect application of � 468A of the Internal Revenue Code with respect to interest in a plant and the related Nuclear Decommissioning Reserve Fund, and to a supplementary request under � 301.9100-3 of the Procedure and Administration Regulations for an extension of time to file a request for a revised schedule of ruling amounts under � 1.468A-3(i)(1)(i) of the Income Tax Regulations. |
| 200452006(PDF, 28K) |
9/9/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election. Specifically, requesting an extension to elect under � 1.1502-75(a)(1) to file a consolidated Federal income tax return with includible subsidiaries. |
| 200452005(PDF, 22K) |
8/20/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200452004(PDF, 18K) |
8/10/2004 |
| Requesting a ruling concerning individual retirement accounts and deferred annuity contracts and decedent's estate under the Internal Revenue Code. |
| 200452003(PDF, 47K) |
9/13/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make allocations of generationskipping transfer tax exemption. |
| 200452002(PDF, 97K) |
8/27/2004 |
| Requesting rulings under sections 351, 368(a)(1)(C) and 368(a)(1)(D) of the Internal Revenue Code with respect to a proposed transaction. |
| 200452001(PDF, 26K) |
12/24/2004 |
| Requesting an extension of time under section 301.9100-1(c) of the Procedure and Administration Regulations to file the required Form 970, Application to use LIFO Inventory Method for Taxpayer. This request is made in accordance with section 301.9100-3. |
| 200451042(PDF, 58K) |
11/10/2004 |
| Issues: (1) Whether the mailing of Form 8453 with an altered jurat, following the transmission of an electronic return, invalidates the return. (2) Will an altered jurat on the Form 8453 affect the validity of the assessment made based on the electronic return? (3) What procedures should the Internal Revenue Service (Service) follow when it has identified an electronic return with a subsequent Form 8453 containing an altered jurat? (4) Whether an electronic return with an altered jurat on Form 8453 is subject to the frivolous return penalty under section 6702. (5) What procedures should the Service follow when it has issued an erroneous refund based on an electronic return? (6) What collection actions are available to the Service if it identifies an erroneous refund soon after transmitting it to the taxpayer�s bank account or posting it in the mail? (7) Whether the Service may refer the preparer of the electronic return and the associated Form 8453 for a civil investigation under section 7408. |
| 200451041(PDF, 33K) |
11/17/2004 |
| Issue: What is the federal income tax treatment of the recently enacted dairy investment tax credit under �� 71.07(3n) and 71.28(3n) of the Wisconsin Statutes? |
| 200451040(PDF, 96K) |
9/23/2004 |
| Requesting a waiver of the 60-day rollover requirement in section 402(c) of the Internal Revenue Code. |
| 200451039(PDF, 127K) |
9/24/2004 |
| Requesting a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200451038(PDF, 120K) |
9/24/2004 |
| Requesting a waiver of the 60-day rollover requirement in section 402(c) of the Internal Revenue Code. |
| 200451037(PDF, 59K) |
9/23/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200451036(PDF, 51K) |
9/23/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200451035(PDF, 51K) |
9/23/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200451034(PDF, 105K) |
9/24/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200451033(PDF, 175K) |
9/22/2004 |
| Requesting a waiver of the 60-day rollover requirement in section 408(d)(3) of the Internal Revenue Code. |
| 200451032(PDF, 21K) |
8/31/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(9). |
| 200451031(PDF, 24K) |
9/21/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(7). |
| 200451030(PDF, 85K) |
9/30/2004 |
| Issues: (1) Whether investors in a Ponzi scheme that takes the form of debt investments are entitled to amend their returns for an open year to reverse interest income received and reported. (2) Whether "middle tier" investors are entitled to amend their returns for an open year to reverse commissions received and reported. (3) Whether investors may claim a theft loss under � 165 for amounts received and reported as income, but reinvested in the scheme. |
| 200451029(PDF, 57K) |
8/12/2004 |
| Requesting an extension of time under section 2642(g) of the Internal Revenue Code and section 301.9100-3 of the Procedure and Administration Regulations to sever a trust into GST exempt and GST non-exempt trusts, make a �reverse� QTIP election under section 2652(a)(3) with respect to the GST exempt trust and to make an allocation of the generation-skipping transfer (GST) exemption to the GST exempt trust under section 2642(b)(1) and (2). |
| 200451028(PDF, 32K) |
9/10/2004 |
| Requesting an extension of time under sections 301.9100-1 and 301.9100-3 of the Procedure and Administration regulations to file an election under section 856(l) of the Internal Revenue Code to treat subsidiaries as a taxable REIT subsidiary. |
| 200451027(PDF, 21K) |
8/30/2004 |
| Requesting a ruling under � 41 of the Internal Revenue Code. |
| 200451026(PDF, 27K) |
9/10/2004 |
| Relief under �� 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested to make an election to file a consolidated Federal income tax return under � 1.1502-75(a)(1) of the Income Tax Regulations. |
| 200451025(PDF, 30K) |
8/27/2004 |
| Requesting a ruling under � 1362(f) of the Internal Revenue Code. |
| 200451024(PDF, 30K) |
8/25/2004 |
| Requesting an extension of time under � 301.9100-1 of the Procedure and Administration Regulations to file the notice provided under � 20.2056A-10(a)(2) of the Estate Tax Regulations, that the beneficiary of a trust has become a United States citizen. |
| 200451023(PDF, 25K) |
9/9/2004 |
| Requesting an extension of time under Treas. Reg. � 301.9100-3 to file the election and agreement described in �1.1503-2(g)(2)(i) with respect to a dual consolidated loss. |
| 200451022(PDF, 24K) |
9/13/2004 |
| Requesting a ruling on the tax treatment of certain reimbursements made by X to family members of developmentally disabled persons. Specifically, whether the reimbursements are taxable income to the recipients, and whether X must file information returns with respect to the reimbursements. |
| 200451021(PDF, 67K) |
7/30/2004 |
| Requesting rulings regarding the consequences of allocating the proceeds from a stock redemption to the principal, rather than the income, of qualified subchapter S trusts (QSSTs), the consequences of partitioning the redemption proceeds portion of the QSSTs from the corporate stock portion of the QSSTs, and the consequences of merging the redemption proceeds portion of the QSSTs with separate pre-existing trusts which have identical terms and beneficiaries. |
| 200451020(PDF, 34K) |
8/31/2004 |
| Requesting a private letter ruling addressing the question of whether a corporation should be treated as a tax-exempt entity within the meaning of � 168(h) of the Internal Revenue Code. |
| 200451019(PDF, 22K) |
9/2/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200451018(PDF, 25K) |
9/8/2004 |
| 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 Internal Revenue Code. |
| 200451017(PDF, 22K) |
8/5/2004 |
| Requesting an extension of time pursuant to � 301.9100-1(c) of the Procedure and Administration Regulations to elect to be treated as a qualified subchapter S subsidiary (QSub) under � 1361(b)(3) of the Internal Revenue Code. |
| 200451016(PDF, 21K) |
8/5/2004 |
| Requesting an extension of time pursuant to � 301.9100-1(c) of the Procedure and Administration Regulations to elect to be treated as a qualified subchapter S subsidiary (QSub) under � 1361(b)(3) of the Internal Revenue Code. |
| 200451015(PDF, 21K) |
8/5/2004 |
| Requesting an extension of time pursuant to � 301.9100-1(c) of the Procedure and Administration Regulations to elect to be treated as a qualified subchapter S subsidiary (QSub) under � 1361(b)(3) of the Internal Revenue Code. |
| 200451014(PDF, 37K) |
9/2/2004 |
| Requesting a letter ruling on the continuing employment exception to the Medicare portion of the Federal Insurance Contributions Act (FICA) taxes under Internal Revenue Code (Code) section 3121(u)(2)(C). |
| 200451013(PDF, 27K) |
9/8/2004 |
| Requesting rulings as to certain federal income tax consequences of a consummated transaction. |
| 200451012(PDF, 37K) |
8/6/2004 |
| Requesting rulings under �� 355 and 368 of the Internal Revenue Code with respect to a proposed transaction. |
| 200451011(PDF, 24K) |
7/22/2004 |
| Requesting a ruling under � 1362(f) of the Internal Revenue Code. |
| 200451010(PDF, 26K) |
8/10/2004 |
| Requesting a ruling that the rental income received by a company from property is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. This ruling would effectively update PLR 200024044 (June 16, 2000) to reflect a revised lease. |
| 200451009(PDF, 23K) |
9/9/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code |
| 200451008(PDF, 25K) |
9/13/2004 |
| Requesting an extension of time under section 301.9100-1(c) of the Procedure and Administration Regulations to file the required Form 970, Application to use LIFO Inventory Method. This request is made in accordance with section 301.9100-3. |
| 200451007(PDF, 47K) |
8/27/2004 |
| Requesting rulings regarding the gift tax, generation-skipping transfer tax, and income tax consequences of a proposed partition of a trust. |
| 200451006(PDF, 47K) |
8/27/2004 |
| Requesting rulings regarding the gift tax, generation-skipping transfer tax, and income tax consequences of a proposed partition of a trust. |
| 200451005(PDF, 47K) |
8/27/2004 |
| Requesting rulings regarding the gift tax, generation-skipping transfer tax, and income tax consequences of a proposed partition of a trust. |
| 200451004(PDF, 47K) |
8/27/2004 |
| Requesting rulings regarding the gift tax, generation-skipping transfer tax, and income tax consequences of a proposed partition of a trust. |
| 200451003(PDF, 46K) |
8/27/2004 |
| Requesting rulings regarding the gift tax, generation-skipping transfer tax, and income tax consequences of a proposed partition of a trust. |
| 200451002(PDF, 39K) |
8/31/2004 |
| Requesting an extension of time under � 301.9100 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer exemption. |
| 200451001(PDF, 39K) |
8/31/2004 |
| Requesting an extension of time under � 301.9100 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer exemption. |
| 200450058(PDF, 240K) |
9/16/2004 |
| Requesting a ruling concerning the determination of the unfunded current liability deduction limit for a pension plan under section 404(a)(l)(D)(i) of the Internal Revenue Code. |
| 200450057(PDF, 299K) |
9/13/2004 |
| Requesting a private letter rulings under sections 72(t) and 402(c)(9) of the Internal Revenue Code. |
| 200450056(PDF, 175K) |
9/15/2004 |
| Requesting rulings under section 72 of the Internal Revenue Code. |
| 200450055(PDF, 216K) |
9/13/2004 |
| Requesting a waiver of the 60 day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200450054(PDF, 238K) |
9/13/2004 |
| Requesting a ruling concerning the federal income tax treatment under Internal Revenue Code section 414(h)(2) of certain contributions. |
| 200450053(PDF, 168K) |
9/15/2004 |
| Requesting rulings under section 72 of the Internal Revenue Code. |
| 200450052(PDF, 175K) |
9/16/2004 |
| Requesting a waiver of the 60 day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200450051(PDF, 134K) |
9/16/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200450050(PDF, 142K) |
9/15/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200450049(PDF, 34K) |
9/16/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200450048(PDF, 35K) |
9/16/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200450047(PDF, 108K) |
9/13/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200450046(PDF, 172K) |
9/15/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200450045(PDF, 95K) |
9/14/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200450044(PDF, 95K) |
9/14/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200450043(PDF, 98K) |
9/14/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200450042(PDF, 86K) |
9/14/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200450041(PDF, 88K) |
9/13/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(7). |
| 200450040(PDF, 61K) |
9/13/2004 |
| Requesting letter rulings concerning section 501(c)(9) of the Internal Revenue Code. |
| 200450039(PDF, 139K) |
9/14/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200450038(PDF, 108K) |
9/14/2004 |
| Denied request for exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200450037(PDF, 130K) |
9/17/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200450036(PDF, 72K) |
12/10/2004 |
| Requesting a ruling on the proper treatment of contributions of business holdings by a disqualified person which ultimately results in a combined ownership in excess of the permitted holdings under section 4943 of the Internal Revenue Code. |
| 200450035(PDF, 35K) |
9/17/2004 |
| Issue: Whether the payment made by Transferor to Taxpayer to relocate and remove electric transmission lines is a nonshareholder contribution to capital under � 118(a) of the Internal Revenue Code. |
| 200450034(PDF, 40K) |
8/19/2004 |
| Requesting an extension of time pursuant to � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make allocations of Husband�s and Wife�s generation-skipping transfer tax exemptions. |
| 200450033(PDF, 38K) |
8/17/2004 |
| Requesting a ruling concerning the federal gift and estate tax consequences of a Court Order construing and modifying an article of a trust. |
| 200450032(PDF, 29K) |
8/26/2004 |
| Request concerning whether plan participants (or their beneficiaries) have income as a result of a company guarantee of the taxpayer�s obligation under a certain plan. |
| 200450031(PDF, 20K) |
8/16/2004 |
| Requesting an extension of time under Treas. Reg. � 301.9100-1 to elect the provisions of section 911 of the Internal Revenue Code. |
| 200450030(PDF, 30K) |
8/26/2004 |
| Requesting that the Commissioner make a determination, under � 1.1502-75(b)(2) of the Income Tax Regulations, that the subsidiaries have joined in the making of an initial consolidated return. |
| 200450029(PDF, 26K) |
8/3/2004 |
| Requesting an extension of time under �301.9100-1 of the Procedure and Administration Regulations to file Form 8328 (Carryforward Election of Unused Private Activity Bond Volume Cap) to make a carryforward election under � 146(f) of the Internal Revenue Code with respect to unused private activity bond volume cap. |
| 200450028(PDF, 33K) |
8/23/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested in order to allow an election to apportion part of a � 382 limitation under � 1.1502-95(c). |
| 200450027(PDF, 30K) |
9/1/2004 |
| Requesting an extension of time under �� 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an election under � 2057(b)(1)(B) of the Internal Revenue Code. |
| 200450026(PDF, 24K) |
8/19/2004 |
| Requesting a ruling under section 1362(f) of the Internal Revenue Code. |
| 200450025(PDF, 20K) |
8/26/2004 |
| Requesting an extension of time under Treas. Reg. � 301.9100-3 to file the election agreement described in �1.1503-2(g)(2)(i). |
| 200450024(PDF, 37K) |
9/1/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations and � 2642(g) of the Internal Revenue Code to make a timely allocation of generation-skipping transfer exemption with respect to a transfer made to a charitable lead unitrust. |
| 200450023(PDF, 57K) |
7/28/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations and � 2642(g) of the Internal Revenue Code to make an allocation of the generation-skipping transfer exemption. |
| 200450022(PDF, 19K) |
8/5/2004 |
| Requesting an extension of time pursuant to � 301.9100-1(c) of the Procedure and Administration Regulations for an election to become a qualified subchapter S subsidiary (QSub) under � 1361(b)(3) of the Internal Revenue Code. |
| 200450021(PDF, 20K) |
8/5/2004 |
| Requesting an extension of time pursuant to � 301.9100-1(c) of the Procedure and Administration Regulations for an election to become a qualified subchapter S subsidiary (QSub) under � 1361(b)(3) of the Internal Revenue Code. |
| 200450020(PDF, 19K) |
8/5/2004 |
| Requesting an extension of time pursuant to � 301.9100-1(c) of the Procedure and Administration Regulations for an election to become a qualified subchapter S subsidiary (QSub) under � 1361(b)(3) of the Internal Revenue Code. |
| 200450019(PDF, 35K) |
8/17/2004 |
| Requesting an extension of time pursuant to � 301.9100-3 of the Procedure and Administration Regulations to file Form 8328, Carryforward Election of Unused Private Activity Bond Volume Cap, to make a carryforward election under � 146(f) of the Internal Revenue Code of an unused private activity bond volume cap. |
| 200450018(PDF, 54K) |
8/17/2004 |
| Requesting a private letter ruling concerning the federal income tax consequences of a proposed transaction. |
| 200450017(PDF, 19K) |
7/22/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200450016(PDF, 28K) |
8/17/2004 |
| Requesting rulings on certain federal income tax consequences of a proposed transaction. |
| 200450015(PDF, 42K) |
8/31/2004 |
| Requesting rulings concerning the Federal income tax consequences of a proposed transaction. |
| 200450014(PDF, 24K) |
12/10/2004 |
| Requesting that the taxpayer's Form 8716 be considered timely filed under the authority of � 301.9100-3 of the Procedure and Administration Regulations. |
| 200450013(PDF, 29K) |
8/25/2004 |
| 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. |
| 200450012(PDF, 35K) |
8/26/2004 |
| Requesting rulings regarding a proposed transaction, including that the proposed transaction qualifies as a reorganization under section 368(a)(1)(F). |
| 200450011(PDF, 24K) |
8/23/2004 |
| Requesting an extension of time under � 301.9100 of the Procedure and Administration Regulations for X to file an election under � 754 of the Internal Revenue Code. |
| 200450010(PDF, 50K) |
8/18/2004 |
| Requesting a ruling concerning the application of sections 451(a) and 457(e)(11) of the Internal Revenue Code. |
| 200450009(PDF, 38K) |
9/1/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and �� 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer exemption. |
| 200450008(PDF, 26K) |
8/30/2004 |
| Requesting a ruling under � 216 of the Internal Revenue Code. |
| 200450007(PDF, 18K) |
9/2/2004 |
| Requesting a ruling that salaries, wages, and similar remuneration paid to employees of a certain employer, an agency of the government of a foreign country, are exempt from U.S. taxation under the income tax treaty between the United States and that country. |
| 200450006(PDF, 18K) |
9/2/2004 |
| Requesting a ruling that salaries, wages, and similar remuneration paid to employees of a certain employer, an agency of the government of a foreign country, are exempt from U.S. taxation under the income tax treaty between the United States and that country. |
| 200450005(PDF, 37K) |
8/30/2004 |
| Requesting a ruling that sport utility vehicles will be treated as like kind to passenger automobiles for purposes of section 1031 of the Internal Revenue Code and the regulations thereunder. Also requesting a ruling that the deferred like-kind exchange program meets the assignment safe harbor and notice requirements in section 6.02 of Rev. Proc. 2003-39, 2003-22 IRB 971. |
| 200450004(PDF, 25K) |
9/1/2004 |
| Requesting a ruling regarding a qualified terminable interest property election under � 2056(b)(7) of the Internal Revenue Code. |
| 200450003(PDF, 53K) |
7/2/2004 |
| Requesting the following rulings: (1) Taxpayer is not required to treat a pool account as a �joint� account for purposes of the withholding provisions under sections 1441, 1442, 1443, 1445, 1446, and 3406 of the Internal Revenue Code (Code). Taxpayer may determine its withholding obligations separately for each pool participant. Consequently, Taxpayer may determine its sections 1441, 1442, 1443, 1445, 1446, and 3406 withholding requirements according to: (i) the amount of income paid to each pool participant; and (ii) the documentation (e.g., Form W-8BEN, etc.) provided by each pool participant. Further, Taxpayer need not obtain an intermediary tax form (Form W-8IMY) for a pool. (2) Taxpayer is not required to treat a pool account as a �joint� account for purposes of its Form 1042-S or Form 1099 reporting requirements under sections 1461, 6041, 6042, 6045, and 6049 of the Code. Taxpayer may determine such reporting obligations according to the amounts paid to, and withheld from (if any), each pool participant. |
| 200450002(PDF, 22K) |
8/3/2004 |
| Requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations, to be granted an extension of time to file an election under section 301.7701-3(c). |
| 200450001(PDF, 41K) |
4/4/2003 |
| Requesting advice concerning a Form 886A. |
