| 200114046(PDF, 26K) |
4/6/2001 |
| Regarding the tax treatment of certain payments that the Federal Emergency Management Agency (FEMA) may make to individuals and businesses in New Mexico that suffered losses due to the Cerro Grande Fire. |
| 200114045(PDF, 14K) |
4/6/2001 |
| Regarding the tax treatment of certain payments that individuals in New Mexico who suffered losses due to the Cerro Grande Fire have received from FEMA or their insurers. |
| 200114044(PDF, 30K) |
4/6/2001 |
| Issue: (1) The amounts paid to recipients who collect only their additional living expenses from their insurance company because of the loss of use of their home due to the fire are received under an insurance contract. |
| 200114034(PDF, 18K) |
4/6/2001 |
| Issues: (1) Whether the Automated Discharge System (ADS) improperly determines that penalties are dischargeable where the debtor has filed previous bankruptcies. |
| 200114033(PDF, 16K) |
4/6/2001 |
| Issues: (1) Does suspension of interest under Internal Revenue Code § 6404(g) apply to a document which qualifies as a frivolous return under I.R.C. § 6702 if the IRS treats the document as a valid return for purposes of the statute of limitations? |
| 200114032(PDF, 6.7K) |
4/6/2001 |
| In which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement and annual certification as described in § 1.1503-2A(c)(3) for the Tax Years Ended #1, #2, and #3. |
| 200114031(PDF, 6.4K) |
4/6/2001 |
| Requesting a ruling that X be given an extension of time to elect to be classified as an association taxable as a corporation for federal tax purposes. |
| 200114030(PDF, 10K) |
4/6/2001 |
| Requesting a ruling that the rental income received by X from renting certain properties will not constitute passive investment income within the meaning of � 1362(d)(3) of the Internal Revenue Code. |
| 200114029(PDF, 8.7K) |
4/6/2001 |
| Incorporated in State on D1. X elected to be treated as a subchapter S corporation effective D2. On D4, X discovered that it had been administratively dissolved by State on D3 for failure to file its annual corporate report. |
| 200114028(PDF, 8.8K) |
4/6/2001 |
| Requesting that X be given an extension of time in which to elect to be treated as a partnership for federal tax purposes as of D1. The information submitted states that X is a foreign eligible entity within the meaning of § 301.7701-3(b) of the Procedure and Administration Regulations and that X was intended to elect to be classified as a partnership for federal tax purposes as of D1. |
| 200114027(PDF, 8.8K) |
4/6/2001 |
| Taxpayer may compute its credit for increasing research activities (research credit) for the taxable year ending December 31, 1999, using the calculation described in § 41(a)(1) of the Internal Revenue Code without regard to § 41(c)(4). Taxpayer is an accrual basis taxpayer with a calendar year. |
| 200114026(PDF, 18K) |
4/6/2001 |
| Requesting a ruling on the generation-skipping transfer tax consequences of a proposed reformation of Trusts 1-4. On May 20, 1992, Trustor created trusts for the benefit of her children and grandchildren under a single trust agreement. |
| 200114025(PDF, 21K) |
4/6/2001 |
| Requesting, on behalf of Parent, an extension of time under §301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent, a State Z corporation, is the common parent of a consolidated group that has a calendar tax year and uses the accrual method of accounting. |
| 200114024(PDF, 11K) |
4/6/2001 |
| 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. |
| 200114023(PDF, 7.4K) |
4/6/2001 |
| Submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated under State law. X's shareholders intended that X be a subchapter S corporation, effective D1; however, an s corporation election under § 1362 was not timely filed. |
| 200114022(PDF, 7.2K) |
4/6/2001 |
| Requesting an extension of time under § 301.9100 of the Procedure and Administration Regulations to elect to treat Y as a qualified subchapter S subsidiary for federal tax purposes. |
| 200114021(PDF, 7.4K) |
4/6/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated under State law. X's shareholders intended that X be a subchapter S corporation, effective D1; however, an S corporation election under § 1362 was not timely filed. |
| 200114020(PDF, 8.3K) |
4/6/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1. X intended to be treated as an S corporation for federal income tax purposes effective on D1, but the S election was not timely filed. |
| 200114019(PDF, 7.9K) |
4/6/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date (1) The sole shareholder of X desired that X elect S corporation treatment effective on Date 1. |
| 200114018(PDF, 7.4K) |
4/6/2001 |
| Requesting a ruling that X's S corporation election will be effective as of the taxable year beginning D1. |
| 200114017(PDF, 7.1K) |
4/6/2001 |
| Requesting a ruling that X be granted an extension of time under � 301.9100-1 and 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. |
| 200114016(PDF, 16K) |
4/6/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer, as one of the owners of the Plant, has a interest as a tenant in common. |
| 200114015(PDF, 12K) |
4/6/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Commission A decreased the amount of decommissioning costs included in Taxpayer's cost of service. |
| 200114014(PDF, 13K) |
4/6/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. |
| 200114013(PDF, 16K) |
4/6/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Commission A decreased the amount of decommissioning costs included in Taxpayer's cost of service. |
| 200114012(PDF, 18K) |
4/6/2001 |
| Issues: (1) The Authority Bonds are not paid from substantially the same source of funds as the City Bonds within the meaning of § 1.150-1(c)(1)(iii) of the Income Tax Regulations. (2) The obligations comprising the Authority Bonds will not be treated as part of the same issue of obligations as the obligations comprising the City Bonds within the meaning of § 1.150-1(c); and (3) The obligations comprising the City Bonds will not be treated as part of the same issue as the obligations comprising the Authority Bonds within the meaning of § 1.150-1(c). |
| 200114011(PDF, 16K) |
4/6/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Commission A decreased the amount of decommissioning costs included in Taxpayer's cost of service. |
| 200114010(PDF, 6.7K) |
4/6/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year 1. |
| 200114009(PDF, 10K) |
4/6/2001 |
| Requesting relief under � 1362(f) of the Internal Revenue Code. X incorporated under the laws of State on D1 and elected to be treated as a subchapter S corporation effective D1. |
| 200114008(PDF, 21K) |
4/6/2001 |
| Issues: (1) Should commissions paid to employees for obtaining new cellular telephone service customers be capitalized pursuant to § 263? (2) Should losses incurred by the taxpayer from the sale of equipment at less than fair market value to newly-acquired customers be capitalized under § 263? |
| 200114007(PDF, 7.1K) |
4/6/2001 |
| Requesting rulings under � 1362(b)(5) and 1362(f) of the Internal Revenue Code. Y and Z, a married couple in a community property state established T on D1. |
| 200114006(PDF, 29K) |
4/6/2001 |
| Issue: Whether employment tax assessments in the name and employer identification number (EIN) of a single member limited liability company are valid assessments against the company's sole owner under the cInternal Revenue Codeumstances described below. |
| 200114005(PDF, 21K) |
4/6/2001 |
| Concerning whether Decedent's interests in certain real estate qualify as an interest in a closely held business for purposes of � 6166 of the Internal Revenue Code (Code). You had also requested a ruling on � 2057 of the Code, but the office of the Assistant Chief Counsel (Passthroughs and Special Industries) informed you that it is declining to rule on that matter until regulations are issued. |
| 200114004(PDF, 25K) |
4/6/2001 |
| Requested rulings concerning the application of the "qualified payment" requirement of § 2701 of the Internal Revenue Code. Prior to a, Taxpayer, Spouse, Son, and Daughter were the limited partners of the Partnership. Company, which is wholly-owned by Taxpayer, was the sole general partner. |
| 200114003(PDF, 10K) |
4/6/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200114002(PDF, 106K) |
4/6/2001 |
| Company, a mutual life insurance company within the meaning of § 816(a) of the Internal Revenue Code, is the common parent of an affiliated group that has elected under § 1504(c)(2) to file a life-nonlife consolidated federal income tax return with its subsidiaries. |
| 200114001(PDF, 28K) |
4/6/2001 |
| Initially, � 6039(a) of the Code required that every corporation make a return to the Internal Revenue Service in connection with the transfer or recordation of transfer of a share of stock acquired by any person pursuant to their exercise of a qualified stock option or a restricted stock option. |
| 200113033(PDF, 42K) |
3/25/2001 |
| This is in response to the ruling request dated May 2, 2000, as supplemented by letters dated October 5, 2000, and November 13, 2000, in which your authorized representative has requested rulings on your behalf concerning the required minimum distributions from contacts described in � 403(b) of the Internal Revenue Code owned by Individual A at the time of his death and held by Company R. |
| 200113032(PDF, 39K) |
3/24/2001 |
| This is in response to the ruling request dated May 2, 2000, as supplemented by letters dated October 5, 2000, and November 13, 2000, in which your authorized representative has requested rulings on your behalf concerning the required minimum distributions from contacts described in � 403(b) of the Internal Revenue Code owned by Individual A at the time of his death and held by Company R. |
| 200113031(PDF, 15K) |
3/30/2001 |
| The Service accepted an offer in compromise from the taxpayers in 1995. The offer in compromise contained the standard language in which the taxpayers promised to comply with all provisions of the Internal Revenue Code relating to the filing of returns and payment of taxes for five years following the acceptance of the offer. |
| 200113029(PDF, 30K) |
3/30/2001 |
| Issue: Under what cInternal Revenue Codeumstances may the Internal Revenue Service provide outstanding lien payoff amounts to title insurance companies, mortgage lenders, and other third parties. |
| 200113028(PDF, 20K) |
3/30/2001 |
| Issues: (1) Whether the Service can impose the two or ten-year disallowance period for claiming EITC, as provided under � 32(k)(1)(B), without imposing a penalty under either � 6662 or � 6663. (2) Whether there is an underpayment for purposes of imposing the penalties under � 6662 or � 6663 when a claim for EITC is frozen and subsequently disallowed. |
| 200113027(PDF, 19K) |
3/30/2001 |
| Issue: Whether a claim for taxes payable post-petition in a Chapter 13 case can be filed as one for administrative expenses, entitled to first-priority status pursuant to B.C. § 507(a)(1), or whether such a claim can only be filed as one pursuant to B.C. § 1305(a)(1), entitled to eighth-priority status pursuant to B.C. § 507(a)(8). |
| 200113026(PDF, 31K) |
3/30/2001 |
| Issue Presented: Does the B.C. § 523(a)(1)(B) exception to discharge for taxes apply to taxes which are based on substitutes for returns (SFRs) prepared by the Service pursuant to Internal Revenue Code § 6020 where the taxpayer signs either a Form 870 or a Form 4549? |
| 200113025(PDF, 20K) |
3/30/2001 |
| Facts: In the early 1990's, several X individuals subscribed to investments in Y securities promoted by X and Y promoters (including A). Apparently the promoters were not complying with securities regulations and in year 1 the Z Office handed down a criminal indictment against the promoters and began forfeiture proceedings against them. |
| 200113024(PDF, 34K) |
3/30/2001 |
| This is in answer to your inquiry about the employment classification of certain elected and/or appointed officials of State. |
| 200113023(PDF, 4.6K) |
3/30/2001 |
| Requesting permission to change their accounting period, for federal income tax purposes. The taxpayers have requested that the Form 1128 be considered timely filed under the authority contained in §301.9100-3 of the Procedure and Administration Regulations. |
| 200113022(PDF, 17K) |
3/30/2001 |
| Whether certain proposed distributions from a variable annuity contract are part of a series of substantially equal periodic payments and are therefore not subject to the 10% penalty on premature distributions from annuity contracts under § 72(q) of the Internal Revenue Code. Taxpayer was born on DATE (1) On DATE 2, he invested a lump sum of money into a variable annuity contract issued by COMPANY. The money invested was not a rollover from a qualified plan or from an IRA; it was from personal savings. |
| 200113021(PDF, 4.5K) |
3/30/2001 |
| Requesting permission to adopt a tax year, for federal income tax purposes. The partnership has requested that the Form 1128 be considered timely filed under the authority contained in §301.9100-3 of the Procedure and Administration Regulations. |
| 200113020(PDF, 16K) |
3/30/2001 |
| Requesting certain rulings regarding the proper federal income tax treatment, including any reporting and/or withholding obligations, for certain fellowship grants and stipends paid by you, X, to individuals in connection with the fellowship training programs and activities briefly described below. You, X, are a tax-exempt, non-profit educational organization organized under the laws of State M, and accredited by N, a federally recognized agency responsible for the accreditation of curricula in the area of your expertise. |
| 200113019(PDF, 18K) |
3/30/2001 |
| To effect the separation of Business B, Distributing has proposed the following series of steps (collectively, the "Proposed Transaction"): (i) Distributing will transfer its Business B assets to newly formed Controlled in exchange for all of Controlled's stock and the assumption by Controlled of the liabilities associated with the Business B assets (the "Transfer"); |
| 200113018(PDF, 10K) |
3/30/2001 |
| Requesting an extension of time to make an election under � 1361(b)(3)(B) of the Internal Revenue Code to treat Subs1, Sub 2, and Subs3 as qualified subchapter S subsidiaries (QSubs). |
| 200113017(PDF, 7.1K) |
3/30/2001 |
| Requesting a ruling supplementing and affirming the rulings granted in PLR-114099-99 ("Prior Ruling"), specifically, rulings under § 355 of the Internal Revenue Code (the "Code") and other Code sections. Ultimately, the transactions resulted in Distributing Sub 1 becoming a first tier, wholly owned subsidiary of Distributing. |
| 200113016(PDF, 57K) |
3/30/2001 |
| Issue: Whether the transactions described below lack economic substance. A sold certain property (Property) to a Country A entity and leased the Property back for a period of approximately #1 years beginning in Date 1. |
| 200113015(PDF, 66K) |
3/30/2001 |
| Submitted by your representative on behalf of Feeder Fund 1 requesting various rulings with respect to the formation of a master-feeder structure. |
| 200113014(PDF, 67K) |
3/30/2001 |
| Submitted by your representative on behalf of Feeder Fund 4 requesting various rulings with respect to the formation of a master-feeder structure. |
| 200113013(PDF, 62K) |
3/30/2001 |
| Submitted by your representative on behalf of Feeder Fund 2 requesting various rulings with respect to the formation of a master-feeder structure. |
| 200113012(PDF, 67K) |
3/30/2001 |
| Submitted by your representative on behalf of Series 2 requesting various rulings with respect to the formation of a master-feeder structure. |
| 200113011(PDF, 62K) |
3/30/2001 |
| Submitted by your representative on behalf of Series 1 requesting various rulings with respect to the formation of a master-feeder structure. |
| 200113010(PDF, 62K) |
3/30/2001 |
| Submitted by your representative on behalf of Trust requesting various rulings with respect to the formation of a master-feeder structure. |
| 200113009(PDF, 38K) |
3/30/2001 |
| The proposed transactions will not cause the Life trust or the New Life Trusts to fail to be exempt from tax under � 501(a) as organizations described in � 501(c)(9). |
| 200113008(PDF, 19K) |
3/30/2001 |
| Revised schedule of ruling amounts in accordance with � 1.468A-3(i)(1)(iii) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on December 1, 1998. |
| 200113007(PDF, 33K) |
3/30/2001 |
| Ruling concerning the federal gift, generation-skipping transfer, and income tax consequences of the proposed merger of Trust A and Trust B. |
| 200113006(PDF, 21K) |
3/30/2001 |
| Rulings concerning the income, gift and estate tax consequences of a proposed severance of a trust ("Trust") under §§ 1001, 2033, 2036, 2037, 2038, 2501, and 2601 of the Internal Revenue Code. |
| 200113005(PDF, 27K) |
3/30/2001 |
| Issue: Whether the memorandum proposed by Area Counsel, through the National Field Coordinator for the National Abusive Trust Project, should be issued and a sample motion to dismiss for failure to state a claim upon which relief can be granted and a sample motion to withdraw the motion to dismiss for failure to state a claim can be posted on the abusive trust website? |
| 200113004(PDF, 47K) |
3/30/2001 |
| Issues: (1) Whether the failure to send the taxpayer's authorized representative a copy of a notice entitling the taxpayer to a Collection Due Process (CDP) hearing, or a Collection Appeals Program (CAP) hearing notice would justify reversal or prohibition of a collection action? (2) Whether any corrective action should be taken if the authorized representative is not sent a copy of a notice entitling the taxpayer to a CDP or CAP hearing, and the procedural failure is not discovered by the Internal Revenue Service (IRS) until the hearing or the date the hearing is requested? |
| 200113003(PDF, 19K) |
3/30/2001 |
| Issues: (1) Does the repeal of � 6621(c) of the Code, dealing with tax motivated transaction interest, necessarily stop any further tax motivated transaction interest from accruing after the repeal date on a previously assessed substantial underpayment? (2) Can hot interest under the current � 6621(c) of the Code accrue simultaneously with tax motivated transaction interest under the former � 6621(c)? (3) Do the hot interest provisions of � 6621(c) apply to an increase in tax liability resulting from an adjustment of a partnership item? If so, what is the applicable date for the start of hot interest accrual? |
| 200113002(PDF, 45K) |
3/30/2001 |
| Issues: (1) Whether, notwithstanding the expiration of the statute of limitations for assessments, the self-employment tax may be re-assessed on the basis that such tax was originally reported by the taxpayer on a timely return. (2) If not, whether self-employment tax may be considered an appropriate offset (under Lewis v. Reynolds, 284 U.S. 281 (1932)) to an income tax refund claim filed after the expiration of the statute of limitations for assessment of self-employment tax? (3) If an offset is appropriate, whether a procedure needs to be devised by which the net amount of the refund may be processed. (4) If an offset is appropriate, whether a procedure needs to be devised for ensuring that the taxpayer receives credit with the Social Security Administration for the self-employment income. |
| 200113001(PDF, 10K) |
3/30/2001 |
| Issues: (1) Does § 2002 of the Internal Revenue Service Restructuring and Reform Act of 1998, which enacted § 6071(b) of the Internal Revenue Code, eliminate the necessity for electronic filers of information returns to request a filing date extension from February 28 to March 31? (2) Will the extension apply to Form W-2 which, in a leap year, is due on February 29? (3) Does § 6071(b) apply to information returns (such as Forms 1042S, 5498, and 5498-MSA) that are due on dates other than February 28? If so, what is the extended due date for these returns? (4) If the extended due date falls on a weekend, will the due date be the next business day? |
| 200112065(PDF, 111K) |
3/23/2001 |
| This is in reply to your request for rulings with respect to the federal income tax consequences of the pledge by A to B of an option to purchase Es common stock (the "Option"), and subsequent transfer to, and exercise by, an unrelated � 501 (c)(3) organization, under � 170, 511. 4940, 4941 and 4942 of the Internal Revenue Code of 1986. |
| 200112064(PDF, 427K) |
3/22/2001 |
| This is in reply to your request for rulings with respect to the federal income tax consequences of the pledge by A to B of an option to purchase KS common stock (the "Option"), and subsequent transfer to, and exercise by, an unrelated � 501 (c)(3) organization, under � 170, 511, 4940, 4941 and 4942 of the Internal Revenue Code of 1986. |
| 200112063(PDF, 36K) |
3/21/2001 |
| This is in reply to a ruling request, as modified, made on your behalf by your authorized representative, that statutory Benefits (as defined below) are "applicable health benefits" under � 420(e)(l)(C) of the Internal Revenue Code of 1986. |
| 200112062(PDF, 26K) |
3/23/2001 |
| Revised schedule of ruling amounts in accordance with � 1.468A-3(i)(1)(iii) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on December 1, 1998. |
| 200112061(PDF, 6.5K) |
3/23/2001 |
| Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of (the taxpayers), requesting permission to change their accounting period, for federal income tax purposes. |
| 200112060(PDF, 8.3K) |
3/23/2001 |
| According to the information submitted, 0n Date 1 X incorporated W, a wholly owned subsidiary. From its inception X intended to have W treated as a QSub, but it inadvertently failed to timely file a QSub election for W. |
| 200112059(PDF, 6.5K) |
3/23/2001 |
| Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer, requesting permission to change its accounting period, for federal income tax purposes. |
| 200112058(PDF, 7.9K) |
3/23/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. A, X's sole shareholder, represents that she intended for X to be treated as an S corporation for federal tax purposes effective as of D1 of Year 1, X's first taxable year. |
| 200112057(PDF, 7.2K) |
3/23/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 in Year 1. |
| 200112056(PDF, 9.7K) |
3/23/2001 |
| Requesting a ruling that Corp X and its subsidiaries be permitted to change to the tax book value method of asset valuation for purposes apportioning interest expense for tax years beginning on or after January 1, 2000. |
| 200112055(PDF, 22K) |
3/23/2001 |
| For many years Distributing has been engaged in Business A serving both large and smaller clients. Distributing has outstanding solely common stock, all of which is held by Shareholders A, B, and C or trusts for their benefit |
| 200112054(PDF, 20K) |
3/23/2001 |
| Requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Lossco is requesting an extension to file the election under § 1.382-6(b) of the Income Tax Regulations (the "Election") for Lossco, Subsidiary 1 and Subsidiary 2 with respect to an acquisition of Lossco stock on Date C (the "Change Date Transaction"). |
| 200112053(PDF, 7.9K) |
3/23/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date (1) The shareholders of X desired that X elect S corporation treatment effective on Date 1, but the election to be treated as an S corporation was not timely filed. |
| 200112052(PDF, 20K) |
3/23/2001 |
| Requested as to the federal income tax consequences of a proposed transaction. The X franchiser requires that the franchisee be an individual. Shareholder 1, individually, is the franchisee for the franchises operated by Distributing. |
| 200112051(PDF, 11K) |
3/23/2001 |
| Requesting an extension of time to make an election under § 42(g)(1) of the Internal Revenue Code pursuant to § 301.9100-1 of the Procedure and Administration Regulations. |
| 200112050(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112049(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112048(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112047(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112046(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112045(PDF, 8.1K) |
3/23/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year (1) A represents that X's shareholders intended for X to be treated as an S corporation for federal tax purposes as of Year 1, X's first taxable year. |
| 200112044(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112043(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112042(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112041(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112040(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112039(PDF, 8.1K) |
3/23/2001 |
| Submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1. X intended to be treated as an S corporation for federal income tax purposes effective on D1, but the S election was not timely filed. |
| 200112038(PDF, 35K) |
3/23/2001 |
| Requested rulings concerning the income, gift, and generation-skipping transfer tax consequences of a Settlement Agreement and the exercise of a limited power of appointment. |
| 200112037(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112036(PDF, 17K) |
3/23/2001 |
| Requesting a ruling regarding the generation-skipping transfer tax consequences of the trustees' proposed renunciation and release of authority. |
| 200112035(PDF, 11K) |
3/23/2001 |
| In which X is requesting a ruling that the rental income received by X from the Properties is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200112034(PDF, 7.5K) |
3/23/2001 |
| This responds to your letter dated November 29, 2000, requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1 and intended to make an election to be treated as an S corporation effective on D1, but the S election was not timely filed. |
| 200112033(PDF, 5.7K) |
3/23/2001 |
| In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer, requesting permission to change its accounting period, for federal income tax purposes. |
| 200112032(PDF, 10K) |
3/23/2001 |
| Submitted on behalf of X, requesting a ruling that the rental income received by X from renting certain properties is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200112031(PDF, 59K) |
3/23/2001 |
| Requesting a ruling on the income, estate, and generation-skipping transfer tax consequences of a proposed reformation of Trust. |
| 200112030(PDF, 38K) |
3/23/2001 |
| Issue: Whether Export Enhancement Program bonus payments received by a U.S. producer with respect to Products exported through the producer's wholly-owned, commission foreign sales corporation ("FSC") qualify as (1) foreign trading gross Receipts under § 924 of the Code, (2) a reduction in cost of goods sold in computing the foreign trading gross receipts of the U.S. producer and its foreign sales corporation, or (3) a non-taxable, non-shareholder capital contribution to the U.S producer under § 118(a) of the Code. |
| 200112029(PDF, 8.5K) |
3/23/2001 |
| Submitted by X's authorized representative on behalf of X, requesting a ruling that X be given an extension of time to elect to be classified as a partnership for federal tax purposes. |
| 200112028(PDF, 20K) |
3/23/2001 |
| Issues: (1) Corporation is an integral part of Authority (a political subdivision of the State) and not subject to federal income taxation. (2) As a state or local governmental unit, Corporation is not required to file federal income tax returns. (3) Alternatively, Corporation's income is excluded from gross income pursuant to � 115 of the Internal Revenue Code. |
| 200112027(PDF, 8.1K) |
3/23/2001 |
| Submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date 1. |
| 200112026(PDF, 16K) |
3/23/2001 |
| For a revised schedule of ruling amounts pursuant to � 1.468A-3( i) of the Income Tax Regulations. Taxpayer is seeking this revised schedule of ruling amounts because compliance with earlier orders promulgated by a public utility commission having regulatory authority over Taxpayer has resulted in a reduction in the amount of amount of decommissioning costs being collected by Taxpayer, and because Taxpayer has sold the Plant. |
| 200112025(PDF, 21K) |
3/23/2001 |
| Requesting a ruling under §170(e)(5)(C) of the Internal Revenue Code with regard to proposed future contributions of qualified appreciated stock to certain private foundations. |
| 200112024(PDF, 21K) |
3/23/2001 |
| Requesting a ruling under §170(e)(5)(C) of the Internal Revenue Code with regard to proposed future contributions of qualified appreciated stock to certain private foundations. |
| 200112023(PDF, 29K) |
3/23/2001 |
| Requesting rulings regarding application of the rules for a qualified personal residence trust in § 2702 and rulings under § 2501, § 2033 and § 2039 of the Internal Revenue Code. |
| 200112022(PDF, 21K) |
3/23/2001 |
| Requesting a ruling under §170(e)(5)(C) of the Internal Revenue Code with regard to proposed future contributions of qualified appreciated stock to certain private foundations. |
| 200112021(PDF, 10K) |
3/23/2001 |
| Requested that, under the cInternal Revenue Codeumstances described below, Company will be a "parent corporation," as that term is used in � 421 through 424 of the Internal Revenue Code, with respect to options granted in its stock to employees of LLC. |
| 200112020(PDF, 58K) |
3/23/2001 |
| Issue: Whether the Lease-in/Lease-out (LILO) transaction described below has economic substance. |
| 200112019(PDF, 10K) |
3/23/2001 |
| Requesting consent for Taxpayer to revoke its election, effective with Taxpayer's Taxable Year c to use the safe harbor method described in § 1.901-2A(c)(3) of the Income Tax Regulations in determining the amount of foreign income tax paid or accrued by Taxpayer to Country A. Taxpayer is a widely held and publicly traded domestic corporation. |
| 200112018(PDF, 21K) |
3/23/2001 |
| Requesting rulings regarding application of the rules for a qualified personal residence trust in § 2702 of the Internal Revenue Code. |
| 200112016(PDF, 26K) |
3/23/2001 |
| Revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts for Commission A on June 26, 1997. |
| 200112015(PDF, 23K) |
3/23/2001 |
| Revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on November 24, 1997. |
| 200112014(PDF, 22K) |
3/23/2001 |
| Requesting a ruling that the conversion of a mutual life insurance company to a stock life insurance company will qualify under � 368(a)(1)(E) of the Internal Revenue Code . |
| 200112013(PDF, 37K) |
3/23/2001 |
| Requesting a ruling that Authority is an integral part of Tribe for purposes of §§ 7701(a)(40) and 7871(a) of the Internal Revenue Code. |
| 200112012(PDF, 26K) |
3/23/2001 |
| Revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts for Commission A on June 26, 1997. |
| 200112011(PDF, 30K) |
3/23/2001 |
| Issues: (1) Whether the United Kingdom Windfall Tax ("UKWT") enacted on July 2, 1997, and imposed on certain British utilities, is a creditable income tax within the meaning of Code � 901(a) and 902(a)(1). (2) Whether the UKWT should be deducted from post-1986 undistributed earnings in the year paid or in the year accrued. |
| 200112010(PDF, 6.4K) |
3/23/2001 |
| Reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer, requesting permission to change its accounting period, for federal income tax purposes. |
| 200112009(PDF, 18K) |
3/23/2001 |
| Submitted on behalf of Decedent's estate, requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make a qualified terminable interest property (QTIP) election under § 2056(b)(7) of the Internal Revenue Code. In addition, you request a ruling regarding the validity of a reverse QTIP election to be made when the QTIP election is made. |
| 200112008(PDF, 7.7K) |
3/23/2001 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. The information submitted discloses that Company was incorporated on a in State. |
| 200112007(PDF, 16K) |
3/23/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer files a consolidated Federal income tax return with its Parent. Taxpayer directly owns a percent undivided interest in the Plant, which is situated in Location. |
| 200112006(PDF, 10K) |
3/23/2001 |
| Submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(f) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 and elected to be treated as an S corporation effective D2. |
| 200112005(PDF, 57K) |
3/23/2001 |
| Issues: 1) Whether respondent should assert that the Tax Court has jurisdiction under Internal Revenue Code § 6214(b) to consider proposed adjustments to partnership items of a TEFRA partnership for partnership years not before the court in the course of determining a partner's basis in his or her partnership interest. 2) What consideration should respondent give to the partnership items of multi-tiered TEFRA partnerships for the purpose of determining a partner's basis in a partnership interest? |
| 200112004(PDF, 7.3K) |
3/23/2001 |
| Requesting a ruling that X on behalf of Y be given an extension of time to elect to disregard Y as an entity separate from X, its owner, for federal tax purposes. |
| 200112003(PDF, 52K) |
3/23/2001 |
| Issues: (1) Is there a statute of limitations for assessing the penalty under § 6707(a)(1) for failure to register a tax shelter? (2) If the Service obtained details of the shelter and promotion activity through prior administrative actions against the promoter, could the § 6707 penalty now be avoided through a theory of substantial compliance or laches? (3) How is the penalty under § 6707 calculated? (4) What procedural rights exist to contest a penalty assessed under § 6707(a)(1)? |
| 200112001(PDF, 34K) |
3/23/2001 |
| Issues: (1) Whether a tax liability arising from the disallowance of the earned income credit is subject to innocent spouse relief under Internal Revenue Code § 6015(b). (2) Whether a requesting spouse who qualified for innocent spouse relief with respect to unreported income is also entitled to a restoration of the earned income credit that was disallowed because the adjustment to the joint return for unreported income caused total income to exceed the maximum amount for which an earned income credit may be claimed. |
| 200111056(PDF, 32K) |
3/20/2001 |
| Issues: (1) May a taxpayer entitled to claim damages under the Act claim a casualty loss deduction under § 165 of the Internal Revenue Code for damage to personal or business property? May a taxpayer who receives damages under the Act elect under § 1033 to defer gain that would otherwise result from the conversion of property destroyed or damaged into money? (2) May a taxpayer who receives damages under the Act elect under § 1033 to defer gain that would otherwise result from the conversion of property destroyed or damaged into money? (3) May a taxpayer whose principal residence is destroyed apply § 121 to exclude gain that would otherwise result and defer any remaining gain under § 1033? |
| 200111055(PDF, 33K) |
3/20/2001 |
| This is in response to your request for a private letter ruling dated in support of your request, you have submitted the following facts and representations. |
| 200111054(PDF, 56K) |
3/19/2001 |
| This is in response to your request for a private letter ruling dated October 7, 2000, as supplemented by a telephone conversation on November 28, 2000, a document sent by facsimile transmission on December 8, 2000, and correspondence dated December 13, 2000, concerning certain income tax consequences of distributions from three individual retirement arrangements ("IFUs"). You submitted the following facts and representations in support of your request. |
| 200111053(PDF, 39K) |
3/18/2001 |
| This is in response to a request for a private letter ruling, dated July 13, 2000, as supplemented by a letter dated December 21, 2000, submitted on your behalf by your authorized representative, concerning the applicability of � 409(l)(4) of the Internal Revenue Code to an employee stock ownership plan. Your authorized representative submitted the following facts and representations in support of the request. |
| 200111052(PDF, 47K) |
3/17/2001 |
| This is in response to a ruling request dated July 17, 2000, and supplemented December 12, 2000. Both the original ruling request and the supplemental information were submitted on your behalf by your authorized representatives. You are seeking rulings on the federal income tax consequences of a proposed transaction, as more fully set forth below. |
| 200111051(PDF, 43K) |
3/16/2001 |
| This is in response to a ruling request dated July 17, 2000, and supplemented December 12, 2000. Both the original ruling request and the supplemental information were submitted on your behalf by your authorized representatives. You are seeking rulings on the federal income tax consequences of a proposed transaction, as more fully set forth below. |
| 200111050(PDF, 47K) |
3/15/2001 |
| This is in response to your letter dated September 20, 2000, in which you requested certain rulings with respect to a proposed transfer of assets from 6 to C. |
| 200111049(PDF, 44K) |
3/14/2001 |
| This is in response to your letter dated September 20, 2000, in which you requested certain rulings with respect to a proposed transfer of assets from B to C. |
| 200111048(PDF, 44K) |
3/13/2001 |
| Issues: (1) The amendment of the 6 VEBAs for union and salaried employees (and the related Plans) and the use of the assets of the VEBAs to provide post-retirement medical and life benefits (through the payment of premiums or otherwise) for the non-A Participants will not adversely affect the tax-exempt status of A VEBAs for union and salaried employees under � 501 (c)(9) of the Code. (2) The amendment of A VEBAs for union and salaried employees (and the related Plans) and the use of the assets of the VEBAs to provide post-retirement medical and life benefits (through the payment of premiums or otherwise) for the Non-A Participants will not be considered a disqualified benefit under � 4976(b)(l)(C) subject to the excise tax under � 4976 of the Code. |
| 200111047(PDF, 42K) |
3/5/2001 |
| Issues: (1) The amendment of the A VEBAs for union and salaried employees (and the related Plans) and the use of the assets of the VEBAs to provide post-retirement medical and life benefits (through the payment of premiums or otherwise) for the non-A Participants will not adversely affect the tax-exempt status of A VEBAs for union and salaried employees under � 501 (c)(9) of the Code. (2) The amendment of A VEBAs for union and salaried employees (and the related Plans) and the use of the assets of the VEBAs to provide post-retirement medical and life benefits (through the payment of premiums or otherwise) for the Non-A Participants will not be considered a disqualified benefit under � 4976(b)(l)(C) subject to the excise tax under � 4976 of the Code. |
| 200111046(PDF, 42K) |
3/5/2001 |
| Issues: (1) The amendment of the A VEBAs for union and salaried employees (and the related Plans) and the use of the assets of the VEBAs to provide post-retirement medical and life benefits (through the payment of premiums or otherwise) for the non-A Participants will not adversely affect the tax-exempt status of A VEBAs for union and salaried employees under � 501 (c)(9) of the Code. (2) The amendment of A VEBAs for union and salaried employees (and the related Plans) and the use of the assets of the VEBAs to provide post-retirement medical and life benefits (through the payment of premiums or otherwise) for the Non-A Participants will not be considered a disqualified benefit under � 4976(b)(l)(C) subject to the excise tax under � 4976 of the Code. |
| 200111045(PDF, 48K) |
3/13/2001 |
| This is in reply to a ruling request dated March 16, 2000, as amended by a letter dated August 31, 2000 with respect to a proposed transfer of assets from B to C. |
| 200111044(PDF, 35K) |
3/20/2001 |
| Issues: Are payments to individuals that are not members of a Pueblo for a claim of lost wages or lost business income includible in the recipient's gross income? Are payments to a member of a Pueblo for a claim of lost wages or lost business income includible in the recipient's gross income? Are payments for claims of lost business income includible in the recipient's self-employment income for purposes of the Self-Employment Contributions Act (SECA) tax? Are payments for a claim for lost wages includible in the recipient's wages for purposes of employment taxes? Are payments to a Pueblo, member of a Pueblo, or a person whose household includes one or more members of a Pueblo for subsistence losses includible in a recipient's gross income? |
| 200111043(PDF, 38K) |
3/20/2001 |
| Issue: Whether the Service is authorized to refund an overpayment of tax after the period for filing a claim for refund has expired if: 1) The Service previously sent the taxpayer a math error notice adjusting the taxpayer's liability for tax and reducing or eliminating the overpayment of tax claimed on the taxpayer's original return, which was filed before the period for filing a refund claim expired, but the taxpayer later substantiates that his or her tax liability was reported correctly on the original return. 2) The Service previously sent the taxpayer a notice of claim disallowance with respect to the overpayment of tax claimed on the taxpayer's original return, which was filed before the period for filing a refund claim expired, but the taxpayer later substantiates that his or her tax liability was reported correctly on the original return. |
| 200111042(PDF, 8.0K) |
3/20/2001 |
| Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file Form 8279, Election To Be Treated as a FSC or as a Small FSC, pursuant to Temp. Treas. Reg. § 1.921-1T(b)(1), Q&A 1, for the tax year ended on Date A. |
| 200111041(PDF, 8.1K) |
3/20/2001 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to Date B to file an election under § 1.884-2T(d)(4)(i) to increase its earnings and profits by the allocable amount of the earnings and profits of Shareholder as determined under § 1.884-2T(d)(4)(ii). |
| 200111040(PDF, 8.1K) |
3/20/2001 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to Date B to file an election under § 1.884-2T(d)(4)(i) to increase its earnings and profits by the allocable amount of the earnings and profits of Shareholder as determined under § 1.884-2T(d)(4)(ii). |
| 200111039(PDF, 10K) |
3/20/2001 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to file the elections and agreements ("elections") described in § 1.1503-2(g)(2) with respect to losses incurred by Subsidiary's Branches for Tax Years X and Y, as the case may be. |
| 200111038(PDF, 29K) |
3/20/2001 |
| The requested rulings are that (1) the transfer of a life insurance policy by a trust to a limited partnership will not constitute a "transfer for value" under §101 of the Internal Revenue Code and (2) the transaction will not result in the grantors of the trust possessing incidents of ownership under §2042(2) in the insurance contract by virtue of the grantors' limited partnership interest in the limited partnership. |
| 200111037(PDF, 10K) |
3/20/2001 |
| We concluded that interest and dividend income derived in the United States by certain exempt Canadian pension funds and Canadian charitable organizations through pooled investment funds is exempt from U.S. taxation under Article XXI, paragraph 2(b) of the U.S.-Canada Income Tax Treaty (the "Treaty"). Under the facts as originally submitted, Corporation is a corporation organized under the laws of Canada. |
| 200111036(PDF, 10K) |
3/20/2001 |
| Funds request extensions of time pursuant to §301.9100-1(a) of the Procedure and Administration Regulations to elect under � 855(a) of the Internal Revenue Code, and Funds through also request extensions of time to elect under � 851(b). Funds are organized as business trusts under the law of either State 1 or State 2 and are registered as open-end diversified management companies under the Investment Company Act of 1940, 15 U.S.C. � 80a-1 et. seq. |
| 200111035(PDF, 14K) |
3/20/2001 |
| Request an extension of time to make an election under � 108(c) of the Internal Revenue Code. Specifically, you have requested an extension of time to make an election under � 108(c) and § 1.108(c)-1 of the Income Tax Regulations to reduce the basis of depreciable property and to exclude income resulting from the discharge of qualified real property business indebtedness. Partnership is a limited liability company which is treated as a partnership for federal income tax purposes. |
| 200111034(PDF, 14K) |
3/20/2001 |
| Request an extension of time to make an election under � 108(c) of the Internal Revenue Code. Specifically, you have requested an extension of time to make an election under � 108(c) and § 1.108(c)-1 of the Income Tax Regulations to reduce the basis of depreciable property and to exclude income resulting from the discharge of qualified real property business indebtedness. Partnership is a limited liability company which is treated as a partnership for federal income tax purposes. |
| 200111033(PDF, 14K) |
3/20/2001 |
| Requested an extension of time to make an election under � 108(c) and § 1.108(c)-1 of the Income Tax Regulations to reduce the basis of depreciable property and to exclude income resulting from the discharge of qualified real property. Partnership is a limited liability company which is treated as a partnership for federal income tax purposes. |
| 200111032(PDF, 14K) |
3/20/2001 |
| Parent, a State X corporation, is the common parent of a group of corporations that join in the filing of a consolidated income tax return. Sub 1, which engaged in Business A, was a wholly-owned subsidiary of Parent. Sub 2 was a wholly-owned subsidiary of Sub 1. |
| 200111031(PDF, 12K) |
3/20/2001 |
| Taxpayer requests an extension of time to make an election under � 108(c) of the Internal Revenue Code. Specifically, the taxpayer has requested an extension of time to make an election under � 108(c) and § 1.108(c)-1 of the Income Tax Regulations to reduce the basis of depreciable property and to exclude income resulting from the discharge of qualified real property business indebtedness. |
| 200111030(PDF, 13K) |
3/20/2001 |
| Request in which the taxpayer requests an extension of time to make an election under � 108(c) of the Internal Revenue Code. Specifically, the taxpayer has requested an extension of time to make an election under � 108(c) and § 1.108(c)-1 of the Income Tax Regulations to reduce the basis of depreciable property and to exclude income resulting from the discharge of qualified real property business indebtedness. |
| 200111029(PDF, 7.5K) |
3/20/2001 |
| Letter Ruling addressed the federal income tax consequences of a series of proposed transactions intended to separate Business A from Business B. |
| 200111028(PDF, 13K) |
3/20/2001 |
| Requested ruling is as follows: Payments and/or reimbursements of certain operating expenses of six new series of the Corporation (collectively "upper-tier funds") by the Funds pursuant to an annual servicing agreement will not be considered preferential dividends of the Funds under � 562(c) of the Internal Revenue Code of 1986. |
| 200111027(PDF, 9.1K) |
3/20/2001 |
| Which we concluded that interest and dividend income from the United States derived by certain exempt Canadian pension funds and Canadian charitable organizations through a pooled investment fund is exempt from U.S. taxation under Article XXI, paragraph 2(b) of the U.S.-Canada Income Tax Treaty (the "Treaty"). |
| 200111026(PDF, 19K) |
3/20/2001 |
| Rulings on certain federal income tax consequences of a proposed transaction. To accomplish this separation, the taxpayer proposes the following transaction: (i) Distributing will transfer the stock of Sub 6 to Controlled. (ii) Controlled will recapitalize by issuing Class A voting stock and Class B nonvoting common stock in exchange for its present single class of voting common stock (the "Recapitalization"). |
| 200111025(PDF, 50K) |
3/20/2001 |
| Submitted pursuant to Rev. Proc. 2000-1, 2000-1 I.R.B. 4, requesting rulings under § 1031 of the Internal Revenue Code (Code). Taxpayer's business consists of real estate investment and leasing operations. |
| 200111024(PDF, 25K) |
3/20/2001 |
| Rulings under § 368(a)(1)(C) of the Internal Revenue Code on behalf of the above-captioned taxpayers. Acquiring is organized under the laws of State X and registered under the Investment Company Act of 1940 (the "1940 Act") as a diversified, open-end management investment company. |
| 200111023(PDF, 25K) |
3/20/2001 |
| Request for rulings under § 368(a)(1)(C) of the Internal Revenue Code on behalf of the above-captioned taxpayers. Acquiring is organized under the laws of State X and registered under the Investment Company Act of 1940 (the "1940 Act") as a diversified, open-end management investment company. |
| 200111022(PDF, 8.0K) |
3/20/2001 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code that Corporation's S corporation election be effective as of Date. |
| 200111021(PDF, 61K) |
3/20/2001 |
| Ruling 1: Whether each of the Feeder Funds will be deemed to own a proportionate share of each of the assets of its corresponding Master Trust and will be deemed to be entitled to the income of the Master Trust attributable to such share for purposes of determining whether the Feeder Fund satisfies the requirements of §§ 851(b)(2), 851(b)(3), 852(b)(5), 853(a), and 854 of the Internal Revenue Code. |
| 200111020(PDF, 7.1K) |
3/20/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year 1. |
| 200111019(PDF, 10K) |
3/20/2001 |
| Requesting a ruling that rents received by X will not constitute "passive investment income" within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200111018(PDF, 10K) |
3/20/2001 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200111017(PDF, 8K) |
3/16/2001 |
| This letter responds to a letter dated August 7, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200111016(PDF, 8K) |
3/16/2001 |
| This letter responds to a letter dated September 5, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200111015(PDF, 7K) |
3/16/2001 |
| This is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted by you, requesting permission to change your accounting period, for federal income tax purposes, from a taxable year ending, to a taxable year ending, effective. You have requested that the Form 1128 be considered timely filed under the authority contained in §301.9100-3 of the Procedure and Administration Regulations. |
| 200111014(PDF, 58K) |
3/16/2001 |
| Issue: Did the taxpayer, which changed from one method of accounting under § 263A of the Internal Revenue Code to another method of accounting under § 263A, properly revalue its inventories to reflect its change in method of accounting? |
| 200111013(PDF, 20K) |
3/16/2001 |
| This letter responds to your letter, dated June 8, 2000, requesting a ruling that the conversion of a mutual life insurance company to a stock life insurance company will qualify under � 368(a)(1)(E) of the Internal Revenue Code . Additional information was submitted in letters dated August 16 and October 3, 2000. The information submitted is summarized below. |
| 200111012(PDF, 8K) |
3/16/2001 |
| This letter responds to a letter and subsequent correspondence, submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200111011(PDF, 31K) |
3/16/2001 |
| Issue: Whether the transaction at issue should be treated as a sale in Year 1, with
the result that Shareholders A and B must recognize gain in that year. |
| 200111010(PDF, 8K) |
3/16/2001 |
| This is in response to a letter dated March 8, 2000, submitted by X's authorized representative requesting a ruling that Article 21 of the United States - Country A Income Tax Treaty is applicable, and that X's employees are not subject to U.S. income tax. The information submitted for consideration is substantially as set forth below. |
| 200111009(PDF, 10K) |
3/16/2001 |
| This is in response to a letter dated August 7, 2000, and supplemental information dated November 23, 2000, submitted by A's authorized representative requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. The information submitted for consideration is substantially as set forth below. |
| 200111008(PDF, 11K) |
3/16/2001 |
| This responds to your letter of July 7, 2000 and subsequent correspondence, on behalf of Municipality M, requesting a ruling concerning the proposed amended and restated deferred compensation plan (the "Plan") which M intends to be an eligible deferred compensation plan under � 457(b) of the Internal Revenue Code of 1986. M is represented to be a municipal governmental entity described in � 457(e)(1)(A) of the Code. |
| 200111007(PDF, 17K) |
12/28/2001 |
| This is in response to a request for rulings dated April 18, 2001, submitted by your authorized representative requesting relief under §301.9100-3 of the Procedure and Administration Regulations to make the consent dividend election under § 565(a) of the Internal Revenue Code. |
| 200111006(PDF, 7K) |
3/16/2001 |
| This letter responds to a letter, dated July 18, 2000, written on behalf of X, requesting a ruling that X be granted an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election under � 301.7701-3(c) to be treated as a partnership for federal tax purposes. |
| 200111005(PDF, 8K) |
3/16/2001 |
| This is in response to your letter dated, requesting a ruling that A's loss of her long term 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. Additional information was submitted in a letter dated The information submitted for consideration is substantially as set forth below. |
| 200111004(PDF, 19K) |
3/16/2001 |
| This Field Service Advice responds to your memorandum dated August 18, 2000. Field Service Advice is not binding on Examination or Appeals and is not a final case determination. This document is not to be used or cited as precedent. |
| 200111003(PDF, 27K) |
3/16/2001 |
| This Field Service Advice responds to your memorandum dated August 11, 2000. Field Service Advice is not binding on Examination or Appeals and is not a final case determination. This document is not to be used or cited as precedent. |
| 200111002(PDF, 9K) |
3/16/2001 |
| This is in response to a letter dated September 26, 2000, submitted by your authorized representative requesting a ruling under � 877(c) of the Internal Revenue Code that A's loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. The information submitted for consideration is substantially as set forth below. |
| 200111001(PDF, 38K) |
3/16/2001 |
| Issues: (1) Whether a partner in a "trader" partnership may claim as a trade or business expense the operating expenses of the partnership. (2) Whether a partner in a "trader" partnership should treat his ordinary income or losses from the partnership as arising from a passive activity for purposes of � 469. (3) Whether � 163(d) limits the deduction of any interest expense flowing through to a noncorporate partner from a "trader" partnership. |
| 200110034(PDF, 76K) |
3/5/2001 |
| This is in response to the letter submitted on your behalf by your authorized representative, as supplemented by correspondence dated and, in which you request a letter ruling under � 401(a) (91 of the Internal Revenue Code. The following facts and representations support your ruling request. |
| 200110033(PDF, 59K) |
3/13/2001 |
| This is in response to the letter submitted on your behalf by your authorized representative in which you, through your representative, request a series of letter rulings under � 72(t), 401(a)(9) and 408 of the Internal Revenue Code. The following facts and representations support your ruling request. |
| 200110032(PDF, 5K) |
3/13/2001 |
| This document has been pulled by the IRS from public view due to inspection delay. |
| 200110031(PDF, 80K) |
3/6/2001 |
| Issue: Whether Taxpayer changed its method of accounting when it began to deduct certain payments made to pension plans after the end of the tax year, but within the time period described by 5 404(a)(6) of the Internal Revenue Code ("the Code"). |
| 200110030(PDF, 11K) |
3/21/2000 |
| Issue: Whether a hospital whose stated policies are to provide health care services to individuals regardless of their ability to pay satisfies the charity care requirement of the community benefit standard under the operational test in Treasury Regulation § 1.501(c)(3)-1(c)? |
| 200110029(PDF, 7.9K) |
3/21/2000 |
| Issue: If the Internal Revenue Service accepts an offer in compromise, should a service center abate assessment of the compromised tax liability? |
| 200110028(PDF, 7.9K) |
3/21/2000 |
| Issue: Whether the issuance of a notice of final determination denying relief from joint and several liability on a joint income tax return, pursuant to Internal Revenue Code § 6015, constitutes a potential violation of the stay on various actions imposed upon the filing of a bankruptcy petition, pursuant to B.C. § 362. |
| 200110027(PDF, 7.9K) |
3/21/2000 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to file Form 8279, Election To Be Treated as a FSC or as a Small FSC, pursuant to Temp. Treas. Reg. § 1.921-1T(b)(1), Q&A 1, for the tax year beginning on Date A. |
| 200110026(PDF, 7.9K) |
3/21/2000 |
| Requesting relief under � 1362(f) of the Internal Revenue Code. According to the information submitted X is a corporation organized under the laws of State and made a valid S corporation election effective Date 1. |
| 200110025(PDF, 36K) |
3/21/2000 |
| Requesting rulings under � 280G of the Internal Revenue Code. Specifically you requested a ruling whether, under the facts outlined below, the parachute payment made to Executive upon the change of control of Target. |
| 200110024(PDF, 8.9K) |
3/21/2000 |
| Requesting a private letter ruling (PLR) under § 265(a)(2) of the Internal Revenue Code. The ruling requested is, in summary, that X's implementation of the transaction described below as it relates to certain government deferred payment agreements (DPAs) will not affect PLR 8826014, issued to X on March 30, 1988. |
| 200110023(PDF, 27K) |
3/21/2000 |
| Requesting a ruling that PRS be given an extension of time under § 301.9100 of the Procedure and Administration Regulations to elect to adjust the basis of partnership property pursuant to § 754 of the Internal Revenue Code. |
| 200110022(PDF, 8.1K) |
3/21/2000 |
| Issues: (1) Will the issuance of the financing order and the transfer of the securitization property to the Issuer result in gross income to the Company? (2) Will the issuance of the Bonds and the transfer of the proceeds of the Bonds to the Company result in gross income to the Company? (3) Will the Bonds constitute obligations of the Company? |
| 200110021(PDF, 93K) |
3/21/2000 |
| Requesting a ruling that the Bulgarian withholding tax described in Article 34(4) of the Bulgarian Corporate Income Tax Act ("BCITA") imposed on certain income that is not derived from a permanent establishment ("Bulgarian Withholding Tax") qualifies as a tax in lieu of a tax on income under � 903 of the Internal Revenue Code . |
| 200110020(PDF, 10K) |
3/21/2000 |
| Issue: Whether, under the rules of Internal Revenue Code § 83, Company D was entitled to deduct the compensation income recognized by Employees when they sold their callable nonstatutory options for Company C shares to Company C. |
| 200110019(PDF, 6.9K) |
3/21/2000 |
| Issue: Whether the Convention between the United States of America and Canada with Respect to Taxes on Income and Capital (the "Convention") prevents application of the § 59(a)(2) alternative minimum tax ("AMT") foreign tax credit limitation to U.S. citizens who reside in Canada. |
| 200110018(PDF, 12K) |
3/21/2000 |
| Submitted by Taxpayer's authorized representative on behalf of Taxpayer for a revised schedule of ruling amounts in accordance with � 1.468A-3(i)(1)(iii) of the Income Tax Regulations. Taxpayer is sponsored by several utility companies, which are its sole stockholders. Taxpayer is the sole owner of the Plant, which is situated in Location. |
| 200110017(PDF, 23K) |
3/21/2000 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i)(1)(iii) of the Income Tax Regulations. Taxpayer is sponsored by several utility companies, which are its sole stockholders. Taxpayer is the sole owner of the Plant, which situated in Location. |
| 200110016(PDF, 13K) |
3/21/2000 |
| Requesting a ruling that X be granted an extension of time pursuant to � 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as a corporation for federal tax purposes under � 301.7701-3. |
| 200110015(PDF, 7.9K) |
3/21/2000 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200110014(PDF, 24K) |
3/21/2000 |
| Requesting under §301.9100-3 of the Procedure and Administration Regulations an extension of time to file a request for a revised schedule of ruling amounts for Plant under §1.468A-3(a)(5) of the Income Tax Regulations. |
| 200110013(PDF, 13K) |
3/21/2000 |
| Requesting rulings under � 280G of the Internal Revenue Code. Specifically, rulings were requested concerning whether, and to what extent, the amounts paid due to the acceleration of various benefits |
| 200110012(PDF, 24K) |
3/21/2000 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. X incorporated under State law on D1. |
| 200110011(PDF, 59K) |
3/21/2000 |
| Requesting a ruling under § 7704 of the Internal Revenue Code. X is a publicly traded partnership that is an electing 1987 partnership under § 7704(g). |
| 200110010(PDF, 18K) |
3/21/2000 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to make an election. Parent as the common parent of the consolidated group of which Sub was a member is requesting the extension to file a statement of allowed loss under § 1.1502-20(c)(3) of the Income Tax Regulations (sometimes hereinafter referred to as the "Statement" or the "Election") for the taxable year ending on Date B. |
| 200110009(PDF, 8.9K) |
3/21/2000 |
| Requesting rulings under � 280G of the Internal Revenue Code. Specifically, the letter requests rulings that, under the facts outlined below, the merger will not cause a change in ownership or effective control of Corporation; merger will not cause a change in a substantial portion of Corporation's assets; and the provisions of � 280G and 4999 of the Code will not apply to payments that are contingent on the merger. |
| 200110008(PDF, 15K) |
3/21/2000 |
| Issue: Whether an interest in profits from oil and gas well production qualifies as a depletable economic interest and may be received tax free. |
| 200110007(PDF, 12K) |
3/21/2000 |
| Our advice regarding whether the Service should file a claim in the federal receivership proceeding United States v. X. |
| 200110006(PDF, 67K) |
3/21/2000 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code that A's loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200110005(PDF, 24K) |
3/21/2000 |
| The Church has requested a ruling on the federal income tax consequences under � 83 and 451 of the Internal Revenue Code with respect to the Plan. |
| 200110004(PDF, 15K) |
3/9/2001 |
| Issues: (1) The impact, if any, of the 1997 amendment to § 304(a)(1) on the basis-recovery rule of Internal Revenue Code § 1368; and (2) the proper tax treatment of cash received and the proper determination of the basis of stock of Acquiring in a transaction? |
| 200110003(PDF, 125K) |
1/4/2001 |
| Holding substance controls over form, the Tenth CInternal Revenue Codeuit found a petitioner who indirectly received assets from a company later assessed with tax liability, but without means to pay, was a fraudulent transferee. Scott, Transferee v. Commissioner, 2001 U.S. App. LEXIS 75 (10 th Cir. Jan. 4, 2001). |
| 200110002(PDF, 35KB) |
3/9/2001 |
| Issue: Under §118(a) of the Internal Revenue Code, are the bonuses paid to the Taxpayer by the Association non-shareholder contributions to capital? Under §§61 and 451, in what year are take-out bonuses includible in the taxable income of Taxpayer? |
| 200110001(PDF, 49KB) |
3/9/2001 |
| Issues: (1) Whether a raised floor installed during the initial construction of an office building to facilitate the installation of computer systems is personal property under � 168 of the Internal Revenue Code or a structural component of a building? (2) If the raised floor is personal property under � 168, what is the appropriate recovery period? (3) Should Rev. Rul. 74-391, 1974-2 C.B. 9, be reconsidered in light of changes in the business environment since its issuance? |
