| 200144031(PDF, 39K) |
11/1/2001 |
| Issue: For purposes of depreciation classification B, is includible in asset class 20.4 or asset class 20.5 of Rev. Proc. 87-56, 1987-2 C.B. 674? |
| 200144030(PDF, 19K) |
11/1/2001 |
| Issues: 1) If a taxpayer is missing but not legally declared deceased and no estate has been created, to whom should the taxpayer's refund check be issued based on each type of possible filing status in the year to which the refund relates? 2) If a taxpayer is missing, but not legally declared deceased, and filed a joint return with a spouse from whom the taxpayer is divorced, and the taxpayer is remarried, to whom should the refund check be issued? |
| 200144029(PDF, 18K) |
11/1/2001 |
| Issues: (1) Whether the Internal Revenue Service must send annual installment agreement statements ("statement") pursuant to the Internal Revenue Service Restructuring and Reform Act of 1998 ("RRA 1998") to taxpayers in bankruptcy. (2) Whether sending the statement to a taxpayer in bankruptcy violates the automatic stay. |
| 200144028(PDF, 40K) |
11/1/2001 |
| This Chief Counsel Advice responds to your memorandum dated May 17, 2001. In accordance with § 6110(k)(3) of the Internal Revenue Code, this Chief Counsel Advice should not be cited as precedent. |
| 200144027(PDF, 11K) |
11/1/2001 |
| This ruling responds to a letter dated May 16, 2001, submitted on behalf of Funds 1 through 22 (collectively referred to as the "Funds") by their authorized representatives. Each Fund requests consent to revoke, for tax Year F and subsequent calendar years, a previous election made by that Fund under � 4892(e)(4)(A) of the Internal Revenue Code. Additionally, the Funds request that the calculation of each of their required distributions of capital gain net income under � 4982(b)(1) and (e)(2) for the calendar year ending December 31, Year F, be determined on the basis of capital gains and losses realized and recognized during the ten-month period from January 1, Year F, through October 31, Year F. |
| 200144026(PDF, 6.0K) |
11/1/2001 |
| This letter responds to a letter dated March 5, 2001, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200144025(PDF, 7.9K) |
11/1/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200144024(PDF, 5.8K) |
11/1/2001 |
| This letter responds to a letter dated January 22, 2001, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200144023(PDF, 7.5K) |
11/1/2001 |
| This responds to your letter dated June 27, 2001, submitted on behalf of X requesting relief under � 1362(f) of the Internal Revenue Code. |
| 200144022(PDF, 7.1K) |
11/1/2001 |
| This letter responds to a letter dated April 23, 2001, from your authorized representative, submitted on behalf of Company, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200144021(PDF, 12K) |
11/1/2001 |
| Requesting rulings under §§ 1362(d)(3) and 1375(a) of the Internal Revenue Code. |
| 200144020(PDF, 5.8K) |
11/1/2001 |
| This letter responds to a letter dated January 22, 2001, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200144019(PDF, 6.0K) |
11/1/2001 |
| This letter responds to a letter dated February 16, 2001, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200144018(PDF, 17K) |
11/1/2001 |
| Rulings were requested concerning the federal gift and estate tax consequences under §§ 2041 and 2514 of the Internal Revenue Code of a court order modifying a trust agreement. |
| 200144017(PDF, 12K) |
11/1/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200144016(PDF, 12K) |
11/1/2001 |
| This letter responds to a letter dated March 15, 2001, from your authorized representative on behalf of Y, requesting inadvertent termination relief for Y under § 1362(f) of the Internal Revenue Code. |
| 200144015(PDF, 6.1K) |
11/1/2001 |
| This responds to a letter dated April 30, 2001, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200144014(PDF, 12K) |
11/1/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200144013(PDF, 9.9K) |
11/1/2001 |
| This letter responds to a letter dated July 14, 2000, and subsequent correspondence, written on behalf of Subtrust 1 requesting a ruling under � 469 of the Internal Revenue Code regarding the deductibility of certain interest expenses. |
| 200144012(PDF, 7.5K) |
11/1/2001 |
| This letter responds to a letter dated March 15, 2001, requesting a ruling under § 301.9100-3 of the Procedure and Administration Regulations that Company be granted an extension of time to elect to be treated as an association under § 301.7701-3(c) effective Date 1. |
| 200144011(PDF, 5.7K) |
11/1/2001 |
| This responds to your letter dated June 5, 2001, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200144010(PDF, 5.7K) |
11/1/2001 |
| This responds to your letter dated May 30, 2001, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200144009(PDF, 5.7K) |
11/1/2001 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200144008(PDF, 30K) |
11/1/2001 |
| A response to a letter dated February 6, 2001, and prior correspondence, submitted on behalf of the Taxpayers, requesting rulings regarding the generation-skipping transfer tax consequences of a division of trust assets. |
| 200144007(PDF, 15K) |
11/1/2001 |
| Federal Tax Classification of an Agreement requesting a ruling concerning the proposed deferred compensation plan (the "Plan") which Agency A intends to be an eligible deferred compensation plan under � 457(b) of the Internal Revenue Code of 1986. |
| 200144006(PDF, 28K) |
11/1/2001 |
| Issues: (1) Whether, with regard to the foreign tax credit, the amount of foreign income taxes deemed paid under � 902(a) and 960 of the Internal Revenue Code, the amount of the corresponding � 78 "gross up", the classification of income and foreign taxes under � 904 to separate categories of income, and the creditability of the U.K. windfall tax paid by UKSub1, are partnership items of Hybrid JV under � 6231(a)(3). (2) Whether a TEFRA proceeding must be commenced with respect to the Notice of Inconsistent Treatment filed by USPartner2 relating to the creditability of the U.K. windfall tax. |
| 200144005(PDF, 23K) |
11/1/2001 |
| Issue: Whether the Agreement between A and B created a partnership for federal tax purposes, and, if so, whether the partnership created under the Agreement was required to withhold under � 1446. |
| 200144004(PDF, 14K) |
11/1/2001 |
| Issue: In Year 2, X & Y reported gain from the conversion of certain stock in B. The period of limitations for filing a claim for refund for Year 2 has now expired. If there is a determination that the conversion occurred in Year 1 rather than Year 2, can an adjustment be made for Year 2? |
| 200144003(PDF, 60K) |
11/1/2001 |
| Issues: (1) Whether Taxpayer's method of allocating additional � 263A costs to ending inventory is a permitted method of accounting under � 263A. (2) If Taxpayer's method of allocating additional � 263A costs is not permitted, whether the examining agent may require Taxpayer to use a simplified method described in the � 263A regulations. (3) Whether Taxpayer should be granted � 7805(b) relief. |
| 200144002(PDF, 21K) |
11/1/2001 |
| Issue: Where the Service compromised with one or more general partners for the employment tax liabilities of a partnership, can the Service later pursue collection of the unpaid balance of the liabilities from other general partners not party to the compromise agreement? |
| 200144001(PDF, 17K) |
11/1/2001 |
| This letter responds to a letter from your authorized representative dated November 9, 2000, requesting rulings regarding the federal income tax consequences of a proposed transaction. |
| 200143032(PDF, 51K) |
9/21/2001 |
| Issues: (1) Does the Hague Service Convention permit service of an IRS administrative summons in the United Kingdom that would be enforceable through the courts of the United States? (2) If so: a. How does the Hague Service Convention permit an IRS administrative summons to be served in the United Kingdom? b. What are the procedures that examination teams should follow to submit administrative summonses for service in the United Kingdom pursuant to the Hague Service Convention? c. Where should the summons require a US citizen who resides in the United Kingdom to appear to be interviewed? |
| 200143031(PDF, 18K) |
9/19/2001 |
| This written technical assistance is to inform you of our position regarding a lease arrangement at an airport that causes a bond financed parking lot to be privately used for purposes of § 141(b)(1) of the Internal Revenue Code. |
| 200143030(PDF, 17K) |
8/1/2001 |
| Issue: Whether § 162(g)(2) of the limits the deductibility of settlement payments made by A to certain customers in anticipation of lawsuits arising from violations under § 4 of the Clayton Act? |
| 200143029(PDF, 19K) |
8/1/2001 |
| Rulings on certain federal income tax consequences of a proposed transaction. |
| 200143028(PDF, 20K) |
7/31/2001 |
| Rulings regarding a proposed division of Trust, a charitable remainder unitrust, into two separate trusts. |
| 200143027(PDF, 5.9K) |
8/2/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200143026(PDF, 4.8K) |
8/1/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200143025(PDF, 9.5K) |
7/31/2001 |
| Requesting a ruling that District is a political subdivision as defined in Treasury Regulation § 1.103-1(b) and § 170 of the Internal Revenue Code. |
| 200143024(PDF, 4.8K) |
7/30/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200143023(PDF, 9.1K) |
7/23/2001 |
| The ruling requested involves the continued qualification of certain dividends for the dividends-paid deduction under §§ 561 and 852 of the Internal Revenue Code. |
| 200143022(PDF, 9.1K) |
7/22/2001 |
| Requesting a ruling that A's surrender of her U.S. Alien Registration Card (Green Card) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200143021(PDF, 5.0K) |
7/21/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200143020(PDF, 9.1K) |
8/2/2001 |
| A ruling that A's surrender of his U.S. Alien Registration Card (Green Card) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200143019(PDF, 39K) |
8/1/2001 |
| This is in response to your letter dated March 30, 2001, and prior correspondence requesting rulings under §§ 61, 1001, and 2601 of the Internal Revenue Code. |
| 200143018(PDF, 6.2K) |
7/31/2001 |
| This responds to a letter dated July 2, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200143017(PDF, 14K) |
7/30/2001 |
| A ruling request, submitted on behalf of X by its authorized representative, concerning the status of X as a "religious order" for purposes of � 1402(c)(4), 3121(b)(8), and 3401(a)(9) of the Internal Revenue Code. |
| 200143016(PDF, 9.3K) |
7/29/2001 |
| This letter responds to a letter dated March 9, 2001, written on behalf of X by X's authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200143015(PDF, 10K) |
7/28/2001 |
| This letter responds to a letter dated June 11, 2001, submitted on behalf of X by X's authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200143014(PDF, 10K) |
7/27/2001 |
| This is in response to your representative's letter dated January 25, 2001, and subsequent correspondence, submitted on behalf of Decedent's estate, requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make an election under § 2032A of the Internal Revenue Code. |
| 200143013(PDF, 8.7K) |
7/26/2001 |
| This letter responds to your request, dated May 12, 2000, for an extension of time under § 301.9100-1 of the Procedure and Administrative Regulations to make a qualified terminable interest property (QTIP) election under § 2056(b)(7) of the Internal Revenue Code. |
| 200143012(PDF, 10K) |
7/26/2001 |
| A ruling concerning § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200143011(PDF, 14K) |
7/25/2001 |
| A ruling on the application of §§ 2055(f) and 2031(c)(9) of the Internal Revenue Code to the above-named estate. |
| 200143010(PDF, 7.1K) |
7/24/2001 |
| A ruling requesting that X be granted an extension of time in which to elect to treat its first tier subsidiary, Y as a qualified subchapter S subsidiary (Q Sub). |
| 200143009(PDF, 17K) |
7/23/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election on behalf of Purchaser. |
| 200143008(PDF, 14K) |
7/17/2001 |
| Taxpayer asks for a waiver of a reasonable error under � 7702(f)(8) such that the Policies will be treated as life insurance contracts for federal tax purposes. |
| 200143007(PDF, 9.2K) |
7/16/2001 |
| Ruling concerning the income tax consequences of the nonqualified deferred compensation agreement (the "Plan") and a trust agreement (the "Trust") that will be established by X. |
| 200143006(PDF, 12K) |
8/2/2001 |
| Issue: Whether payments made by A to B and C to settle a pending and an anticipated civil suit, respectively, arising from alleged price-fixing and antitrust violations are deductible in full. |
| 200143005(PDF, 41K) |
8/1/2001 |
| Issues: (1) Whether the preparation of a notice of deficiency based upon materials collected and prepared by the Criminal Investigation Division during a grand jury investigation violated the restriction on the disclosure of grand jury matters in Rule 6(e)(2). (2) Whether the Internal Revenue Service should obtain an order authorizing the further release of grand jury materials before using the materials for the preparation and trial of a Tax Court case. |
| 200143004(PDF, 92K) |
7/31/2001 |
| Issues: (1) Whether Donor's family corporation, FC, lacks economic substance and should be disregarded for gift tax purposes. (2) Whether Donor made a gift of the underlying assets of the corporation to the other family shareholders on formation of FC. (3) Whether Donor made indirect gifts of the underlying assets in FC to the extent of the donees' proportionate shares of interests in the corporation, within the meaning of Treasury Regulation §25.2511-1(h)(1). (4) Whether FC should be disregarded as a restriction on the sale or use of the assets contributed by Donor to the corporation, pursuant to � 2703(a)(2). (5) Whether, in the alternative, restrictions in FC documents or under applicable state law on the sale or use of stock should be disregarded when valuing Donor's intrafamily gifts of FC stock, pursuant to � 2703(a)(2). |
| 200143003(PDF, 23K) |
8/1/2001 |
| Issue: A taxpayer overstated its life insurance reserves for a tax year that is now closed. In a subsequent tax year, another taxpayer, with whom the first taxpayer had merged, reduced its life insurance reserves by the amount of the overstatement, but did not take the amount of the overstatement into gross income. Assuming the latter position is sustained by a determination under Internal Revenue Code § 1313(a), do the mitigation provisions of I.R.C. §§ 1311 through 1314 authorize the Internal Revenue Service to adjust the error in the closed tax year? |
| 200143002(PDF, 18K) |
10/26/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not a covered employer under the Railroad Retirement Act. |
| 200143001(PDF, 47K) |
9/21/2001 |
| Issues: (1) Does § 1032 of the Internal Revenue Code bar a corporation that issues its stock to bondholders and unsecured trade creditors in satisfaction of their claims against the corporation from deducting any premium?1 (2) If an expense was paid or incurred by Taxpayer, as a result of the Class 5 creditors exchanging their debt holdings in Taxpayer for newly issued stock in the reorganized Taxpayer, in years subsequent to the bankruptcy court's discharge of Taxpayer's entire liability to the Class 5 creditors, was Taxpayer's deduction for such expenses limited by § 382(h)(6)(B)? (3) Was the exchange with holders of Taxpayer's debentures of Class B common stock in the reorganized Taxpayer a payment by Taxpayer of a deductible interest expense under § 163 of the Code? |
| 200142025(PDF, 19K) |
10/22/2001 |
| Requesting rulings regarding the federal income tax consequences of a proposed transaction. |
| 200142024(PDF, 32K) |
10/22/2001 |
| Issue: Whether a notice of deficiency issued for a nonfiler that is supported by a proposed assessment based on a substitute for return prepared by the Service showing all the income and gains from a Schedule K-1, but not showing any deductions, losses, or credits is valid and, moreover, will be presumed correct and leave the burden of going forward with evidence on the taxpayer? |
| 200142023(PDF, 30K) |
10/22/2001 |
| Criminal investigation disclosure scenarios. |
| 200142022(PDF, 34K) |
10/22/2001 |
| Issues: 1) Whether the additional tax (including the 10 percent additional tax imposed under � 72(t) of the Internal Revenue Code (Internal Revenue Code) for early distributions) due for the taxable year in which taxpayers took a distribution from a traditional IRA to convert the funds to a Roth IRA may be assessed pursuant to the mathematical error procedures, if the reason for the adjustment was that the taxpayer's modified adjusted gross income (AGI) was above the threshold amount permitted for making such a conversion. 2) Whether penalties under Internal Revenue Code § 4973 ensuing as the result of a failed Roth IRA conversion may be assessed under mathematical error procedures. |
| 200142021(PDF, 13K) |
10/22/2001 |
| Issues: (1) Whether there is a statute of limitations on assessment for penalties imposed pursuant to � 6721 and 6722. (2) To the extent there is a statute of limitations on assessment for penalties imposed pursuant to � 6721 and 6722, whether the statute has run with respect to the filing of Forms 1099-MISC. |
| 200142020(PDF, 50K) |
10/22/2001 |
| Fifth Amendment privilege not violated by filing requirement. |
| 200142019(PDF, 19K) |
10/22/2001 |
| This responds to your letter dated September 13, 2000, incorporating some of the material contained in your letter dated June 28, 2000, and other supplemental material, in which you request rulings related to §§ 61 and 170 of the Internal Revenue Code. |
| 200142018(PDF, 26K) |
10/22/2001 |
| Requesting private letter rulings concerning the renewable electricity production credit under § 45 of the Internal Revenue Code. |
| 200142017(PDF, 6.2K) |
10/22/2001 |
| Requesting a ruling under § 1362(b)(requesting a ruling under § 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200142016(PDF, 11K) |
10/22/2001 |
| Requesting an extension of time, under � 1.9100-3 of the Income Tax Regulations, for Fund to make the election under � 855(a) of the Internal Revenue Code and � 1.855-1(b)(1). |
| 200142015(PDF, 6.6K) |
10/22/2001 |
| Request for a private letter ruling, submitted on behalf of X, requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200142014(PDF, 12K) |
10/22/2001 |
| Requesting consent to Taxpayer's revocation of its election under � 831(b)(2)(A)(ii) of the Internal Revenue Code. |
| 200142013(PDF, 12K) |
10/22/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200142012(PDF, 17K) |
10/22/2001 |
| This letter responds to a letter dated Date A, submitted on your behalf by your authorized representative, in which rulings were requested regarding certain federal income tax consequences of a proposed transaction. |
| 200142011(PDF, 13K) |
10/22/2001 |
| Requesting rulings under § 642 of the Internal Revenue Code. |
| 200142010(PDF, 8.8K) |
10/22/2001 |
| Requesting a ruling that X be given an extension of time to elect to be treated as a partnership for federal tax purposes. |
| 200142009(PDF, 7.1K) |
10/22/2001 |
| Requesting a ruling that X be given an extension of time to elect to be classified as a partnership for U.S. tax purposes. |
| 200142008(PDF, 20K) |
10/22/2001 |
| Decline to grant consent for a application for change in method of accounting. |
| 200142007(PDF, 31K) |
10/22/2001 |
| Issue: (1) Whether media rights acquired in connection with the acquisition of Taxpayer, a professional sports franchise, in Year 1 are an asset separate and distinct from goodwill? |
| 200142006(PDF, 21K) |
10/22/2001 |
| Issues: (1) Is there tension between the literal terms of Internal Revenue Code § 7425(d)(1) and Treasury Regulation § 30Issues: 1.7425-4(a)(3) as to whether a Notice of Federal Tax Lien ("NFTL") must be properly filed more than 30 days before a nonjudicial such sale in order for the Internal Revenue Service to have a right of redemption? (2) Whether a NFTL filed outside of the chain of title still meets the requirements of I.R.C. § 6323(f)(4)? |
| 200142005(PDF, 64K) |
10/22/2001 |
| Issues: (1) Whether Taxpayer is entitled to "amortize" the Forward Treasury Rate-Lock Payment (received from Counterparty on the day after the Determination Date) under Treasury Regulation § 1.446-4, rather than include it in income in the taxable year of receipt. (2) If Taxpayer is entitled to "amortize" the Forward Treasury Rate-Lock Payment under Treas. Reg. § 1.446-4, whether Taxpayer is entitled to do so over a period based on the Stated Maturity Date of the Debt Securities, rather than the Remarketing Date. (3) Whether Taxpayer is entitled to "amortize" the Remarketing Payment (received from Remarketing Agent when Taxpayer issued the Debt Securities), rather than include it in income in the taxable year of receipt. |
| 200142004(PDF, 9.6K) |
10/22/2001 |
| Request for a ruling concerning the treatment of your retirement plan under � 1402(a)(10) of the Internal Revenue Code (Code). |
| 200142003(PDF, 84K) |
10/22/2001 |
| This is a year end summary of Criminal Tax Bulletin Items for calendar years 1998, 1999, and 2000. |
| 200142002(PDF, 92K) |
10/22/2001 |
| Suspect barred from entering his home while warrant sought to search for drugs. |
| 200142001(PDF, 34K) |
10/22/2001 |
| Issues: (1) Whether an information document request (IDR) issued during the planning stage of an examination, which specifically identifies an accounting method or sub-method as an area of potential adjustment, constitutes written notification that the method or sub-method is an issue under consideration in the subsequent examination. (2) Whether a broad statement in an IDR renders the entire IDR invalid for purposes of placing an issue under consideration, even when the IDR contains other statements that are specific. (3) If the entire IDR is not rendered invalid, whether Taxpayer received written notification prior to filing its Form 3115, Application for Change in Accounting Method, that specifically cited the method that was the subject of the Form 3115 as an issue under consideration in the subsequent examination. |
| 200141045(PDF, 18K) |
10/12/2001 |
| Requesting rulings on the federal income tax consequences of a proposed transaction. |
| 200141042(PDF, 8.1K) |
10/12/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 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. |
| 200141040(PDF, 17K) |
10/12/2001 |
| This is in reply to your letter dated May 24, 2001 requesting rulings on a proposed transaction. |
| 200141039(PDF, 12K) |
10/12/2001 |
| This letter responds to a letter dated April 3, 2001, submitted on behalf of Parent requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200141038(PDF, 6.2K) |
10/12/2001 |
| This responds to a letter dated June 19, 2001, and subsequent correspondence requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200141036(PDF, 19K) |
10/12/2001 |
| A ruling that $x ( Payments ) per month to be paid by you to Former Spouse is alimony under � 71 of the Internal Revenue Code of 1986 ( Code ) and is thus deductible by you, as Taxpayer, under � 215 of the Code. |
| 200141035(PDF, 9.5K) |
10/12/2001 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election to be treated as a corporation for federal tax purposes, and relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200141033(PDF, 6.9K) |
10/12/2001 |
| This letter responds to a letter, dated November 29, 2000, written on behalf of X, 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(c). |
| 200141032(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased being an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective December 31, 1998. |
| 200141031(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective December 6, 2000. |
| 200141030(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective January 1, 2001. |
| 200141029(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective January 2, 2001. |
| 200141028(PDF, 7.5K) |
10/12/2001 |
| Requesting a ruling that X's rental income from the Property is not passive investment income within the meaning of § 1362(d)(3)(C)(i) and § 1375(a) of the Internal Revenue Code. |
| 200141026(PDF, 21K) |
10/12/2001 |
| This Chief Counsel Advice responds to your memorandum dated April 12, 2001. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200141025(PDF, 5.7K) |
10/12/2001 |
| This responds to your letter dated May 24, 2001, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200141024(PDF, 14K) |
10/12/2001 |
| Requesting a ruling regarding the generation-skipping transfer ( GST ) tax consequences of the Trustee's proposed reconstitution of a single trust estate into three trust estates pursuant to the terms of the trust instrument. |
| 200141023(PDF, 6.1K) |
10/12/2001 |
| This responds to a letter dated May 11, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200141022(PDF, 21K) |
10/12/2001 |
| Rulings concerning the federal income, gift, and generation-skipping transfer tax consequences of the proposed division of a trust. |
| 200141021(PDF, 14K) |
10/12/2001 |
| Is the partnership's Y year Federal income tax return subject to the audit procedures of Internal Revenue Code § 6221 through 6234 ("TEFRA") or is the partnership exempt from those procedures under the "small partnership exception" to the TEFRA rules? |
| 200141020(PDF, 24K) |
10/12/2001 |
| Issue: Whether X's winnings from the State A lottery are exempt from withholding under � 871 and 1441 because of Article 20(2) of the Income Tax Convention between the United States and Israel (Treaty). |
| 200141019(PDF, 17K) |
10/12/2001 |
| We are responding to the following ruling that you have requested: X will be entitled to a charitable contribution deduction under § 170 of the Internal Revenue Code upon the exercise of the Option (whether by Y or by a Permitted Transferee) in an amount equal to the difference between the exercise price and the fair market value of the Common Stock received upon the exercise of the Option, on the date of exercise, subject to the limitations under § 170(b)(2) on the amount of a charitable contribution deduction allowed a corporation. |
| 200141018(PDF, 17K) |
10/12/2001 |
| You are seeking rulings on the federal income tax consequences of the proposed transaction. |
| 200141016(PDF, 17K) |
10/12/2001 |
| This letter responds to the request, dated March 9, 2000, submitted on behalf of Taxpayer by its authorized representative, for a revised schedule of ruling amounts. |
| 200141015(PDF, 31K) |
10/12/2001 |
| Issues: (1) Whether Decedent's estate fails to qualify for an extension of time to pay estate taxes under � 6166 because the Stock Transfer Restriction Agreement requires a series of redemptions of stock held by the estate representing an interest in a closely held business. (2) Whether a redemption required by the Stock Transfer Restriction Agreement constitutes a distribution, sale, exchange, or other disposition of an interest in a closely held business under � 6166(g)(1)(A). (3) Whether the failure of Decedent's estate to timely make an interest payment provides sufficient cause for the Service Center to issue notice and demand under � 6166(g)(3)(A), thereby terminating the estate's installment privileges. |
| 200141014(PDF, 11K) |
10/12/2001 |
| Issue: Whether a wage levy was either an erroneous levy from the outset or became an erroneous levy when it was resumed after the Service had accepted an offer in compromise from the taxpayer. |
| 200141013(PDF, 23K) |
10/12/2001 |
| Refund of estate tax overpayment vs. crediting overpayment to remaining Internal Revenue Code § 6166 installments. |
| 200141012(PDF, 24K) |
10/12/2001 |
| Issue: Whether the Service can obtain a waiver of a taxpayer's right to receive the notice of termination of an installment agreement required by Internal Revenue Code § 6159(b)(5)? |
| 200141011(PDF, 53K) |
10/12/2001 |
| Issues: (1) If an erroneous refund was generated by the abatement of dischargeable liabilities pursuant to a Chapter 7 discharge, but prior to a distribution by the trustee of funds that should have been applied to those dischargeable liabilities, is a reversal of the abatement permissible? (2) If so, whether a reversal of abatement would violate the discharge injunction? (3) Whether the filing of a suit to collect the erroneous refund violates the discharge injunction of B.C. § 524(a)(2)? |
| 200141010(PDF, 43K) |
10/12/2001 |
| Issues: (1) Whether for purposes of sourcing US Co's income under � 863(b) US Co produces Products 1 and 2 in Mexico. (2) Whether for purposes of sourcing US Co's income under � 863(b) the activities of US Co's Mexican controlled foreign corporations, Maquila 1 and Maquila 2, pursuant to the agreements between US Co, Maquila 1, and Maquila 2, may be attributed to US Co. |
| 200141009(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200141008(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective September 30, 1999. The RRB also held that ceased being a covered employer under the Acts effective September 29, 1999. |
| 200141007(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not a common carrier under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200141006(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective October 24, 1997. |
| 200141005(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective July 5, 1999. |
| 200141004(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200141003(PDF, 18K) |
10/12/2001 |
| How are the earnings and profits of a foreign corporation determined in a foreign functional currency (including both previously taxed earnings and profits (PTI) and taxable earnings and profits (nonPTI)) translated into U.S. dollars when distributed in a � 301 distribution pursuant to a � 304 transaction? |
| 200141002(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective February 4, 2000. |
| 200141001(PDF, 18K) |
10/12/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that and became employers under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective October 8, 1999. The RRB also held that is not an employer under the Acts. |
| 200140086(PDF, 59K) |
4/12/2002 |
| This is in reply to your rulings request of May 2, 2000, concerning T's proposed transfer of all of its assets to C pursuant to � 507(b)(2) of the Internal Revenue Code. |
| 200140085(PDF, 40K) |
4/12/2002 |
| This is in reply to your rulings request of September 15, 2000, on Ts proposed transfer of all of its assets to C pursuant to � 507(b)(2) of the Internal Revenue Code. |
| 200140084(PDF, 59K) |
4/12/2002 |
| We have considered your ruling request dated January 16, 2001 requesting a ruling regarding a proposed transfer of assets under � 507(b)(2) of the Internal Revenue Code. |
| 200140083(PDF, 49K) |
4/12/2002 |
| We have considered your ruling request dated September 18, 2000 regarding a private foundation's transfer of all of its assets to several transferee foundations under � 507(b)(2) of the Code. |
| 200140082(PDF, 39K) |
4/12/2002 |
| This is in response to the letter, submitted by you in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations. |
| 200140081(PDF, 162K) |
10/6/2001 |
| By failing to object before the bankruptcy court to its retention of jurisdiction over the debtor's action to determine tax liability, the Government waived the right to contest jurisdiction on appeal, according to the Ninth CInternal Revenue Codeuit in Kieslich v. United States, 2001 U.S. App. LEXIS 17215 (9 th Cir. Aug. 2, 2001). |
| 200140080(PDF, 24K) |
10/6/2001 |
| Issue: Whether a trust whose governing instrument does not authorize the trustee to make charitable contributions may claim a charitable deduction for its distributive share of a charitable contribution made by a partnership, in which the trust is a partner. |
| 200140079(PDF, 14K) |
10/6/2001 |
| Issue: Whether the current Form 4868 and accompanying instructions should be revised to insure that payments are properly applied when a taxpayer seeks an extension for income and gift tax. |
| 200140078(PDF, 87K) |
10/6/2001 |
| Issues: Whether the Service can reconstruct tip income of casino floor personnel from information either a) developed by the Service currently to determined the tip income of casino food and beverage employees, or b) determined during previous casino rate reviews for such personnel? Whether the burden of proof will shift under � 7491(b) if the Service reconstructs a casino floor personnel's tip income solely from information either a) developed by the Service currently to determined the tip income of casino food and beverage employees, or b) determined during previous casino rate reviews for such personnel? |
| 200140077(PDF, 6.0K) |
10/6/2001 |
| This letter responds to your representative's letter dated February 6, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200140076(PDF, 6.1K) |
10/6/2001 |
| This letter responds to your letter dated March 30, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200140075(PDF, 5.8K) |
10/6/2001 |
| This responds to a letter dated March 10, 2001, submitted on behalf of X, requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200140074(PDF, 9.5K) |
10/6/2001 |
| Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 as follows (i) to file the elections, agreements and certifications required under § 1.1503-2(g)(2)(i) for the fiscal tax year ended on date A. |
| 200140071(PDF, 6.1K) |
10/6/2001 |
| This letter responds to your representative's letter dated November 14, 2000, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200140070(PDF, 12K) |
10/6/2001 |
| This letter responds to a letter dated November 14, 2000, submitted on behalf of X, requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200140069(PDF, 5.8K) |
10/6/2001 |
| This letter responds to a letter dated November 22, 2000, requesting a ruling on behalf of X under § 1362(b)(5) of the Internal Revenue Code. |
| 200140068(PDF, 11K) |
10/6/2001 |
| Requesting rulings about the federal income tax consequences of a proposed transaction. |
| 200140067(PDF, 8.5K) |
10/6/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 ( Code ) 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. |
| 200140066(PDF, 6.6K) |
10/6/2001 |
| This letter responds to a letter, dated April 13, 2001, 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 disregarded entity for federal tax purposes. |
| 200140065(PDF, 6.9K) |
10/6/2001 |
| The purpose of this letter is to inform you that LTR 200015015 is hereby modified in accordance with � 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1 (January 2, 2001). |
| 200140064(PDF, 5.7K) |
10/6/2001 |
| This responds to your letter dated January 31, 2001, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200140063(PDF, 7.4K) |
10/6/2001 |
| The purpose of this letter is to inform you that LTR 200015016 is hereby revoked in accordance with � 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1 (January 2, 2001). |
| 200140062(PDF, 7.4K) |
10/6/2001 |
| On January 6, 2000, the Internal Revenue Service issued LTR 200015014 (PLR-114797-99) to Fund. The purpose of this letter is to inform you that LTR 200015014 is hereby revoked in accordance with � 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1 (January 2, 2001). |
| 200140061(PDF, 8.1K) |
10/6/2001 |
| On January 6, 2000, the Internal Revenue Service issued LTR 200015017 (PLR-114792-99) to Fund. The purpose of this letter is to inform you that LTR 200015017 is hereby modified in accordance with � 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1 (January 2, 2001). |
| 200140060(PDF, 7.4K) |
10/6/2001 |
| On January 6, 2000, the Internal Revenue Service issued LTR 200015013 (PLR-114796-99) to Fund. The purpose of this letter is to inform you that LTR 200015013 is hereby revoked in accordance with � 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1 (January 2, 2001). |
| 200140059(PDF, 6.6K) |
10/6/2001 |
| This letter responds to a letter, dated April 30, 2001, 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 disregarded entity for federal tax purposes. |
| 200140058(PDF, 6.6K) |
10/6/2001 |
| This letter responds to a letter, dated April 23, 2001, 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. |
| 200140057(PDF, 15K) |
10/6/2001 |
| Issues: This is in response to your authorized representatives' submission of February 28, 2001, and subsequent submissions, requesting rulings that (1) certain extended service contracts sold by Taxpayer are insurance contracts for federal income tax purposes, (2) Taxpayer is an insurance company for federal income tax purposes, and (3) Taxpayer will be entitled to deduct (as reinsurance premiums) amounts paid to an unaffiliated insurance company. |
| 200140056(PDF, 5.9K) |
10/6/2001 |
| This letter responds to a letter dated March 20, 2001, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200140055(PDF, 6.1K) |
10/6/2001 |
| This responds to a letter dated May 22, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200140054(PDF, 5.7K) |
10/6/2001 |
| This responds to your letter dated June 5, 2001, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200140052(PDF, 4.6K) |
10/6/2001 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending December 31, to a taxable year ending January 31, effective January 31, 2000. |
| 200140051(PDF, 8.5K) |
10/6/2001 |
| This is in response to A's letter dated February 22, 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. |
| 200140050(PDF, 10K) |
10/6/2001 |
| This letter responds to a letter dated February 28, 2001, and subsequent correspondence requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200140049(PDF, 35K) |
10/6/2001 |
| This Chief Counsel Advice responds to your memorandum dated April 6, 2001. In accordance with Internal Revenue Code § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200140048(PDF, 8.6K) |
10/6/2001 |
| This letter responds to your representative's letter dated March 19, 2001 and subsequent correspondence, submitted on behalf of X, requesting a time extension under � 301.9100-3 of the Procedure and Administration Regulations for X to elect to be treated as an association taxable as a corporation for federal tax purposes and relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200140047(PDF, 5.9K) |
10/6/2001 |
| This responds to a letter dated January 5, 2001, and additional correspondence, submitted on behalf of X, requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200140046(PDF, 12K) |
10/6/2001 |
| This letter responds to your January 16, 2001 request for a private letter ruling, submitted on behalf of Trust, requesting rulings on the transactions described. |
| 200140045(PDF, 6.3K) |
10/6/2001 |
| This responds to a letter dated June 4, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200140044(PDF, 9.6K) |
10/6/2001 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code and requesting an extension of time for Company to elect to treat Subsidiary as a qualified subchapter S subsidiary under § 1361(b)(3). |
| 200140043(PDF, 11K) |
10/6/2001 |
| According to the information submitted, X is a State1 corporation, incorporated in Year1. X elected subchapter S status for Federal tax purpose, effective D1. |
| 200140042(PDF, 17K) |
10/6/2001 |
| This is in reply to your representative's letter of Date J, requesting rulings as to the federal income tax consequences of a proposed transaction. |
| 200140041(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased being an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective March 31, 2000. |
| 200140040(PDF, 11K) |
10/6/2001 |
| This letter responds to your January 16, 2001 request for a private letter ruling, submitted on behalf of Trust, requesting rulings on the transactions described below. |
| 200140039(PDF, 15K) |
10/6/2001 |
| This is in response to your letter dated February 28, 2001, requesting rulings on behalf of Distributing with respect to a proposed and partly consummated transaction. |
| 200140038(PDF, 11K) |
10/6/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200140036(PDF, 5.7K) |
10/6/2001 |
| This responds to your letter dated February 15, 2001, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200140035(PDF, 4.9K) |
10/6/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200140034(PDF, 5.7K) |
10/6/2001 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200140033(PDF, 22K) |
10/6/2001 |
| This responds to your letter dated January 22, 2001, requesting rulings in connection with a proposed corporate separation pursuant to § 355 of the Internal Revenue Code. These rulings were requested for Distributing, Intermediate, and Controlled. Additional information was received in letters dated April 9, 2001, and June 19, 2001. |
| 200140032(PDF, 23K) |
10/6/2001 |
| This is in reply to a letter from your representative dated January 26, 2001, requesting a ruling that Fund is an integral part of State and that certain payments to Fund made by consumers pursuant to Program will be deductible by them as charitable contributions under § 170 of the Internal Revenue Code. |
| 200140031(PDF, 18K) |
10/6/2001 |
| This letter responds to your letter dated March 21, 2001, requesting on behalf of Taxpayer an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make a "relation-back" election under § 1.468B-1(j)(2)(ii) of the Income Tax Regulations. |
| 200140030(PDF, 12K) |
10/6/2001 |
| This letter responds to a letter dated March 7, 2001, submitted on behalf of Purchaser and Sellers by their authorized representative, requesting an extension of under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser and Sellers are requesting an extension to file a "§ 338(h)(10) election" under §§ 338(g) and 338(h)(10) of the Internal Revenue Code and § 1.338(h)(10)-1(d) of the Income Tax Regulations with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date A. (All citations in this letter to regulations under § 338 are to regulations in effect on Date A.) |
| 200140029(PDF, 12K) |
10/6/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200140028(PDF, 7.7K) |
10/6/2001 |
| This letter responds to the ruling request dated February 28, 2001, submitted on behalf of Taxpayer, requesting 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(c). |
| 200140027(PDF, 21K) |
10/6/2001 |
| This is in response to your letter of May 30, 2001, and other correspondence requesting rulings concerning the proposed transfer of a unitrust interest in Trust to Charity. |
| 200140026(PDF, 20K) |
10/6/2001 |
| This is in reply to a letter dated February 19, 2001, as supplemented by subsequent submissions, requesting two rulings on behalf of Company concerning the treatment of certain income for purposes of § 856(d) of the Internal Revenue Code. This letter addresses only the first ruling requested. The second ruling requested will be addressed in a separate private letter ruling pursuant to § 8.02(1) of Rev. Proc. 2001-1, 2001-1 I.R.B. 1, 27. |
| 200140025(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective June 16, 2000. |
| 200140024(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased being an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective December 31, 1994. |
| 200140023(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective June 1, 1999. |
| 200140022(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200140017(PDF, 15K) |
10/6/2001 |
| Issues: (1) Are amounts expended by B for the tests described below expenses for medical care under § 213(d) of the Internal Revenue Code? (2) May B exclude reimbursements from her medical flexible spending account for the cost of the tests described below? |
| 200140016(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200140014(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective April 17, 2000. |
| 200140013(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased being an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective December 31, 1998. |
| 200140012(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective September 1, 2000. |
| 200140011(PDF, 10K) |
10/6/2001 |
| This letter is in reply to a letter from your authorized representative, dated February 20, 2001, requesting rulings about the federal income tax consequences of a proposed transaction. |
| 200140010(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act and that services performed by its employees are not covered under the Acts. |
| 200140009(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased being a covered employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective February 14, 1998. |
| 200140008(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective August 14, 2000. |
| 200140007(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective January 1, 1995. |
| 200140006(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not a covered employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200140005(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective May 12, 1998, and that became an employer under the Acts effective July 3, 1998. |
| 200140004(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. |
| 200140003(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased to be an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective February 8, 1996. |
| 200140002(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective May 12, 1998. |
| 200140001(PDF, 18K) |
10/6/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective January 1, 2000. |
