2002 Chief Counsel's
Written Determinations
200200000 to 200204999
Taxpayer-specific rulings or determinations are written memoranda furnished by the
IRS National Office in response to requests by taxpayers under published annual
guidelines. Technical advice memoranda are written memoranda furnished by the
National Office of the IRS upon request of a district director or chief appeals officer
pursuant to annual review procedures. Chief Counsel advice are written advice or
instructions prepared by the Office of Chief Counsel and issued to field or service
center employees of the IRS or Office of Chief Counsel.
It is important to note that pursuant to 26 USC § 6110(j)(3), such items cannot be
used or cited as precedent.
All files below are in the Adobe Acrobat PDF Format.
| 200204036(PDF, 12K) |
1/25/2002 |
| This letter responds to a letter dated July 18, 2001, submitted on behalf of Purchaser and Sellers, requesting an extension of time 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)-1T(c) 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 B. (All citations in this letter to regulations under � 338 are to regulations in effect on Date B.) Additional information was received in a letter dated October 15, 2001. The material information is summarized below. |
| 200204035(PDF, 14K) |
1/25/2002 |
| This is in response to a letter dated April 30, 2001, in which rulings were requested regarding the federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated August 28, 2001 and September 5, 2001. The information submitted in the request and in subsequent correspondence is summarized below. |
| 200204034(PDF, 57K) |
1/25/2002 |
| This is in response to your authorized representative�s letter dated April 12, 2001, requesting rulings under �� 355 and 368 of the Internal Revenue Code with respect to a proposed series of transactions, and also requesting a ruling supplementing our letter ruling dated June 21, 2000 (the �Prior Ruling Letter�). Additional information was received in letters dated August 1, 2001, September 7, 2001, September 20, 2001, September 28, 2001, October 9, 2001, and October 15, 2001. The material information submitted is summarized below. |
| 200204033(PDF, 16K) |
1/25/2002 |
| This letter responds to a letter dated August 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. Parent is requesting an extension to file a �� 338 election� under � 338(g) with respect to the acquisition of the stock of Target and the deemed acquisition of the stock of Target Affiliate 1-25 ("Target Affiliates") on Date A (sometimes hereinafter referred to as the �Election�). (All citations in this letter to regulations under � 338 are to regulations in effect on Date A.) Additional information was received in a letter dated September 24, 2001. The material information is summarized below. |
| 200204032(PDF, 13K) |
1/25/2002 |
| This letter is in response to your request for a ruling that the Agency qualifies as a political subdivision of the State for purposes of � 103 of the Internal Revenue Code and that, accordingly, the Agency is not required to file federal income tax returns or pay federal income tax on its income. |
| 200204031(PDF, 6K) |
1/25/2002 |
| This is in reply to a letter dated April 3, 2001, submitted on behalf of X, 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. |
| 200204030(PDF, 18K) |
1/25/2002 |
| This letter responds to a letter dated May 3, 2000, and subsequent correspondence, submitted on behalf of X by its authorized representative, requesting rulings under � 29 of the Internal Revenue Code. |
| 200204029(PDF, 12K) |
1/25/2002 |
| This letter responds to your authorized representative�s letter dated May 3, 2001, requesting rulings on certain federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated October 12, 2001, January 2 and January 30, 2002. |
| 200204028(PDF, 10K) |
1/25/2002 |
| This letter responds to a letter dated May 15, 2001, and subsequent correspondence from your authorized representative on behalf of X, requesting an extension of time for X to elect to treat Y, Z and the Subs, as Qualified Subchapter S Subsidiaries (QSubs) under � 1361(b)(3) of the Internal Revenue Code. |
| 200204027(PDF, 13K) |
1/25/2002 |
| This letter responds to your letter dated April 23, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under � 1362(f) of the Internal Revenue Code. |
| 200204026(PDF, 7K) |
1/25/2002 |
| We received letters dated April 20, 2001, and August 29, 2001, from Taxpayer�s authorized representative requesting permission for Taxpayer to revoke its election under � 41(c)(4) of the Internal Revenue Code. This letter responds to that request. |
| 200204025(PDF, 7K) |
1/25/2002 |
| This letter responds to a letter dated February 15, 2001, and subsequent correspondence by your authorized representative on behalf of X, requesting an extension of time for X to elect to be treated as a disregarded entity under � 301.7701-3 of the Procedure and Administration regulations. |
| 200204024(PDF, 9K) |
1/25/2002 |
| This letter responds to your letter dated March 16, 2001, and subsequent correspondence on behalf of X, requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations for X to file an election to be classified as a partnership for federal tax purposes under � 301.7701-3(c). |
| 200204023(PDF, 9K) |
1/25/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200204022(PDF, 30K) |
1/25/2002 |
| This is in response to your letter dated October 18, 2001 and prior correspondence submitted in which you requested rulings on behalf of Son, Daughter, and Decedent�s estate concerning the application of �� 2518, 2055, and 2056(b)(8) of the Internal Revenue Code. |
| 200204021(PDF, 7K) |
1/25/2002 |
| This responds to your letter of July 6, 2001, on behalf of Employer. You requested rulings concerning the federal income tax treatment of long-term disability benefits paid through the Plan under � 104(a)(3) and 105 of the Internal Revenue Code . |
| 200204020(PDF, 12K) |
1/25/2002 |
| This letter responds to your authorized representative�s letter dated June 20, 2001, requesting, on behalf of Taxpayer, an extension of time under �� 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Taxpayer is requesting an extension to file an election (the �Election�) under � 1.337(d)-5T(b) and (c) to be subject to the rules of � 1374 of the Internal Revenue Code with respect to assets it received from Parent, a C corporation. The material information is summarized below. |
| 200204019(PDF, 7K) |
1/25/2002 |
| This letter responds to your submission dated June 8, 2001, and subsequent correspondence, requesting a ruling under � � 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations that Company be permitted to elect to be classified as a partnership pursuant to � 301.7701-3(c) effective Date 1. |
| 200204018(PDF, 9K) |
1/25/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200204017(PDF, 9K) |
1/25/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200204016(PDF, 9K) |
1/25/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200204015(PDF, 11K) |
1/25/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200204014(PDF, 23K) |
1/25/2002 |
| Issue: Whether interest on Taxpayer�s Year 1 and Year 5 deficiencies should accrue during periods in which Taxpayer was overpaid for subsequent tax years? |
| 200204013(PDF, 10K) |
1/25/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200204012(PDF, 5K) |
1/25/2002 |
| This responds to a letter dated September 12, 2001, submitted on behalf of X, requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200204011(PDF, 8K) |
1/25/2002 |
| This letter responds to your letter dated August 3, 2001, requesting that a transfer of the stock of a subchapter S subsidiary from a first-tier subsidiary to the parent be disregarded for federal income tax purposes. |
| 200204010(PDF, 6K) |
1/25/2002 |
| This letter responds to your letter dated July 3, 2001, as well as subsequent correspondence, requesting a ruling under � 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200204009(PDF, 6K) |
1/25/2002 |
| This letter responds to a letter dated May 23, 2001, and subsequent correspondence, requesting a ruling on behalf of Company under � 1362(b)(5) of the Internal Revenue Code. |
| 200204008(PDF, 25K) |
1/25/2002 |
| Issue: Whether certain amounts incurred by Taxpayer for utilities used in the Research Buildings are qualified research expenses under � 41. |
| 200204007(PDF, 17K) |
1/25/2002 |
| This responds to your request of February 26, 2001, on behalf of the Plan and the State, concerning whether �in-service� disability benefits paid to disabled members of the Plan and to deceased members' beneficiaries are excludable from the gross income of the recipients under � 104(a)(1) of the Internal Revenue Code. |
| 200204006(PDF, 11K) |
1/25/2002 |
| This letter is in response to your submission of June 8, 2001, and subsequent correspondence concerning your request for a private letter ruling pertaining to � 42(d)(2)(B)(ii)(I) of the Internal Revenue Code. You have provided the following representations: |
| 200204005(PDF, 13K) |
1/25/2002 |
| This is in reply to your letter of March 26, 2001, submitted on behalf of LLC #1, in which rulings are requested regarding certain federal income tax consequences of the transactions described below. |
| 200204004(PDF, 8K) |
1/25/2002 |
| This responds to your letter dated August 10, 2001, submitted on behalf of LLC, requesting a ruling that LLC be given an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as a corporation for federal tax purposes. |
| 200204003(PDF, 18K) |
1/25/2002 |
| Issue: For purposes of a claim for equitable relief under � 6015(f) of the Internal Revenue Code, was the Taxpayer�s outstanding tax liability for Year 1 paid on or before April 15 of Year 3? |
| 200204002(PDF, 47K) |
1/25/2002 |
| Issues: (1) Do either of the two separate transactions (Transaction A and Transaction B, defined below) qualify as a tax-free reorganization under �� 368(a)(1)(A) and 368(a)(2)(E) or under � 368(a)(1)(B) of the Internal Revenue Code? (2) Do either Transaction A or Transaction B qualify for nonrecognition treatment under � 351? (3) If � 351 or � 368 do otherwise provide nonrecognition treatment for Transaction A or Transaction B or both, does � 269 deny the benefit of those � to the taxpayer? |
| 200204001(PDF, 26K) |
1/25/2002 |
| Issue: Whether Forms 872 (consents to extend the period of limitations) executed after Target�s merger into Successor Corporation are considered valid if the Forms 872 improperly bore only Target�s name and made no reference to Successor Corporation as successor in interest to Target. |
| 200203068(PDF, 8K) |
1/18/2002 |
| This replies to a letter dated April 18, 2001, submitted on your behalf by your authorized representative, requesting that Taxpayer be granted an extension of time under Treasury Regulation � 301.9100-3 to file the agreement provided under � 1.1503- 2(g)(2)(i), and to file the annual certification required under � 1.1503-2(g)(2)(vi)(B) with respect to the losses incurred by Entities 1 and 2 for Tax Years X, Y and Z. The information submitted for consideration is substantially as set forth below. |
| 200203067(PDF, 5K) |
1/18/2002 |
| This responds to your letter dated April 5, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200203066(PDF, 10K) |
1/18/2002 |
| This is in reply to a letter dated June 28, 2001, requesting an extension of time, under � 1.9100-3 of the Income Tax Regulations, for Funds 1 through 5 (�Funds�) to make the election under � 855(a) of the Internal Revenue Code and � 1.855-1(b)(1). |
| 200203065(PDF, 24K) |
1/18/2002 |
| This letter responds to the request of Taxpayer, dated February 28, 2001, for a 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 May 28, 1999. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200203064(PDF, 24K) |
1/18/2002 |
| This letter responds to the request of Taxpayer, dated February 28, 2001, for a 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 June 8, 1999. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200203063(PDF, 6K) |
1/18/2002 |
| This letter responds to your letter, dated July 2, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200203062(PDF, 24K) |
1/18/2002 |
| This letter responds to the request of Taxpayer, dated February 28, 2001, for a 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 June 21, 1996. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200203061(PDF, 29K) |
1/18/2002 |
| Issues: (1) Whether any portion of the payments received by W in connection with promissory notes given to her in exchange for her marital rights in the stock of C is income to W. (2) Whether C�s incurring and satisfying an obligation to pay W for her marital interest in the stock of C constitutes a constructive distribution to H. (3) If the arrangement constitutes a constructive distribution, does the constructive distribution occur at the time the obligation is incurred or at the time C discharges the obligation, and must H include the distributions in income? Is H entitled to an interest deduction for the interest paid to W? (4) Whether C�s assignments to H of any marital interest it acquired and of its payment obligations have any tax consequences. |
| 200203060(PDF, 9K) |
1/18/2002 |
| This letter is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted for the taxpayer named above, requesting permission to change the taxpayer�s accounting period from a taxable year ending September 30, to a taxable year ending March 31, effective March 31, 2000. The taxpayer has requested that the Form 1128 be considered timely filed under � 301.9100-3 of the Procedure and Administration Regulations. |
| 200203059(PDF, 10K) |
1/18/2002 |
| We respond to a letter dated August 24, 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. The extension is being requested for Parent and Subsidiaries to make an election to file a consolidated Federal income tax return, with Parent as the common parent, under � 1.1502-75(a)(1) of the Income Tax Regulations (Election), effective for their taxable year ending on Date (1) Additional information was received in a letter dated October 12, 2001. The material information submitted for consideration is summarized below. |
| 200203058(PDF, 23K) |
1/18/2002 |
| This letter responds to your June 5, 2001 request for certain rulings on the federal income tax consequences of a series of transactions. |
| 200203057(PDF, 9K) |
1/18/2002 |
| This letter responds to a letter dated March 26, 2001, and subsequent correspondence submitted on behalf of X, requesting inadvertent invalid election relief under � 1362(f) of the Internal Revenue Code. |
| 200203056(PDF, 13K) |
1/18/2002 |
| This letter responds to a letter dated June 25, 2001, submitted on behalf of Seller #1, Seller #2, Seller #3, Seller #4, Seller #5, and Seller #6 (collectively, �Sellers�) and Purchaser, requesting an extension of time 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)-1T(c) 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.) Purchaser has also requested an extension of time under �� 301.9100-1 through 301.9100-3 to file an election to treat Target as a qualified subchapter S subsidiary (�QSub�) pursuant to � 1361(b)(3)(B)(ii). That request will be dealt with in a separate letter. This letter assumes that any election by Purchaser to treat Target as a QSub, if made, will not be effective prior to the day following Date A. Additional information relating to the Purchaser and Sellers� request for an extension to file a � 338(h)(10) election was received in a letter dated August 27, 2001. |
| 200203055(PDF, 5K) |
1/18/2002 |
| This letter responds to your request for a written determination, dated July 31, 2001, requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200203054(PDF, 6K) |
1/18/2002 |
| This responds to your letter dated, October 2, 2001 in which you requested relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200203053(PDF, 55K) |
1/18/2002 |
| Issues: (1) Whether mirror sale-leaseback transactions between two domestic subsidiaries of the taxpayer and two foreign subsidiaries of a foreign bank followed by a like-kind exchange that returned title to the leased properties to Taxpayer�s controlled group lacked economic substance and therefore should be disregarded for federal income tax purposes. (2) Alternatively, whether � 482 applies to reallocate income and deductions from the transactions. (3) If the foreign source rental income created in the foreign property sale-leaseback is not disregarded, whether such income is properly characterized as general limitation income or passive income for foreign tax credit limitation purposes. (4) Whether the accuracy-related penalty under � 6662(a) should be asserted. |
| 200203052(PDF, 9K) |
1/18/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200203051(PDF, 9K) |
1/18/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200203050(PDF, 9K) |
1/18/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200203049(PDF, 9K) |
1/18/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200203048(PDF, 9K) |
1/18/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200203047(PDF, 9K) |
1/18/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200203046(PDF, 9K) |
1/18/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200203045(PDF, 15K) |
1/18/2002 |
| This is in response to your June 13, 2001 letter and other correspondence requesting rulings concerning the gift tax and estate tax consequences of the proposed division of Living Trust. |
| 200203044(PDF, 9K) |
1/18/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200203043(PDF, 9K) |
1/18/2002 |
| This responds to a letter dated May 23, 2001, and subsequent correspondence, submitted on behalf of A, requesting a ruling that the Partners of X will not recognize pre-contribution gain under � 704(c)(1)(B) or � 737(b)(1) as a result of the in-kind distribution of a assets on or after Date 5, that were contributed to the Partnership on Date 4, because the assets were contributed pursuant to a written binding contract for the contribution of a fixed amount of property that was in effect on June 8, 1997, and at all times thereafter before such contribution and thus qualified for transitional relief under � 1063(b)(2) of the Taxpayer Relief Act of 1997. |
| 200203042(PDF, 12K) |
1/18/2002 |
| This responds to the letter written in your behalf, dated January 26, 2001, requesting a ruling on the proper treatment of an exchange, under � 1031 of the Internal Revenue Code, of a Perpetual Conservation Easement (PCE) in real property for a fee interest in other real estate that will also be burdened with a PCE upon receipt. These are the applicable facts: |
| 200203041(PDF, 6K) |
1/18/2002 |
| This letter responds to your letter dated June 27, 2001, as well as subsequent correspondence, requesting a ruling under � 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200203040(PDF, 24K) |
1/18/2002 |
| This letter responds to the request of Taxpayer, dated February 28, 2001, for a 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 June 17, 1996. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200203039(PDF, 24K) |
1/18/2002 |
| This letter responds to the request of Taxpayer, dated February 28, 2001, for a 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 July 22, 1996. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200203038(PDF, 24K) |
1/18/2002 |
| This letter responds to the request of Taxpayer, dated February 28, 2001, for a 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 July 16, 1999. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200203037(PDF, 6K) |
1/18/2002 |
| This responds to a letter dated May 25, 2001, submitted on behalf of X, requesting that X be given an extension of time under � 301.9100-3(a) of the Procedure and Administration Regulations to elect to be disregarded as an entity separate from its owner for federal tax purposes. |
| 200203036(PDF, 7K) |
1/18/2002 |
| This responds to a letter dated May 25, 2001, submitted on behalf of X, requesting that X be given an extension of time under � 301.9100-3(a) of the Procedure and Administration Regulations to elect to be disregarded as an entity separate from its owner for federal tax purposes. |
| 200203035(PDF, 6K) |
1/18/2002 |
| This responds to a letter dated May 25, 2001, submitted on behalf of X, requesting that X be given an extension of time under � 301.9100-3(a) of the Procedure and Administration Regulations to elect to be disregarded as an entity separate from its owner for federal tax purposes. |
| 200203034(PDF, 10K) |
1/18/2002 |
| This letter responds to your October 9, 2000, and subsequent correspondence, written on behalf of X corp, requesting rulings under � 664 for the formation and operation of a charitable remainder unitrust. |
| 200203033(PDF, 11K) |
1/18/2002 |
| This responds to the letter written in your behalf, dated January 26, 2001, requesting a ruling on the proper treatment of an exchange, under � 1031 of the Internal Revenue Code, of a Perpetual Conservation Easement (PCE) in real property for a fee interest in other real estate that will also be burdened with a PCE upon receipt. These are the applicable facts: |
| 200203032(PDF, 29K) |
1/18/2002 |
| This letter responds to a letter dated September 24, 1999, and subsequent correspondence, submitted on behalf of P by its authorized representative, requesting rulings under � 29 of the Internal Revenue Code. |
| 200203031(PDF, 11K) |
1/18/2002 |
| This is in response to your letter dated October 9, 2001, and prior correspondence, requesting an extension of time under � 301.9100-1 of the Procedure and Administration Regulations to make an alternate valuation election under � 2032 of the Internal Revenue Code with respect to Decedent�s estate. |
| 200203030(PDF, 15K) |
1/18/2002 |
| This is in response to your letter dated April 28, 1998, and subsequent correspondence, requesting a ruling concerning the generation-skipping transfer (�GST�) tax consequences of partitioning Trust A pursuant to the Amended Judgment. |
| 200203029(PDF, 12K) |
1/18/2002 |
| This is in response to the March 12, 2001 letter and other correspondence requesting a ruling concerning the generation-skipping transfer tax consequences of the proposed division of a trust. |
| 200203028(PDF, 19K) |
1/18/2002 |
| 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 coverage of the following business terminated effective February 23, 1998: |
| 200203027(PDF, 8K) |
1/18/2002 |
| This letter responds to your letter, dated January 10, 2001, submitted on behalf of Taxpayer, requesting an extension of time under � 301.9100-1 of the Procedure and Administration Regulations to make an election to be treated as a homeowners association under � 528 of the Internal Revenue Code for the taxable years Year 2 through Year (4) Additional information was submitted on behalf of Taxpayer on March 22, 2001 and April 16, 2001. |
| 200203026(PDF, 12K) |
1/18/2002 |
| This replies to your letter on behalf of Subsidiary 1, dated June 5, 2000, and supplemented by a letter dated April 10, 2001, in which you requested a ruling that certain interest received by Subsidiary 3 would not be considered received by a controlled foreign corporation from a related person within the meaning of � 881(c)(3)(C). |
| 200203025(PDF, 18K) |
1/18/2002 |
| 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 August 3, 2000. |
| 200203024(PDF, 19K) |
1/18/2002 |
| 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 1, 2001: |
| 200203023(PDF, 19K) |
1/18/2002 |
| 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 August 31, 1998: |
| 200203022(PDF, 6K) |
1/18/2002 |
| This letter responds to a letter dated June 11, 2001, and subsequent correspondence, requesting a ruling on behalf of Company under � 1362(b)(5) of the Internal Revenue Code. |
| 200203021(PDF, 30K) |
1/18/2002 |
| Issues: (1) Whether a redeemed shareholder�s enjoyment of certain fringe benefits relating to his spouse�s post-redemption employment with the redeeming corporation is a �prohibited interest� in the corporation under Internal Revenue Code � 302(c)(2)(A) that disqualifies him from a waiver of family attribution. (2) Whether an installment note held by the redeemed shareholder that accelerates the installment loan if the redeeming corporation breaches an employment contract with his spouse or a lease between the redeemed shareholder and the corporation is a prohibited interest under I. R.C. � 302(c)(2)(A). (3) Whether a pledge of the redeemed stock held by the redeemed shareholder is a prohibited interest under I. R.C. � 302(c)(2)(A). (4) What if the redeemed shareholder in fact continues to control the operations of the corporation? |
| 200203020(PDF, 18K) |
1/18/2002 |
| Issue: For purposes of determining FSC income, was Corp X reasonable in apportioning certain deductions for compensation paid according to estimated time spent by certain key employees on United States and foreign activities? |
| 200203019(PDF, 6K) |
1/18/2002 |
| Issues: (1) The excise tax imposed by � 4261 of the Internal Revenue Code is not applicable to payments for transportation made or deemed made by Taxpayer to LLC3. (2) The excise tax imposed by � 4261 is not applicable to payments for transportation made or deemed made by LLC1 or LLC2 to LLC3. |
| 200203018(PDF, 22K) |
1/18/2002 |
| This Service Center Advice is in response to a letter to the National Taxpayer Advocate dated July 6, 2000. In accordance with Internal Revenue Code �6110(k)(3), this Service Center Advice should not be cited as precedent. |
| 200203017(PDF, 9K) |
1/18/2002 |
| This letter responds to a letter dated May 17, 2001, as well as subsequent correspondence, submitted on behalf of Company. We have been asked to rule 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. |
| 200203016(PDF, 24K) |
1/18/2002 |
| Issues: What is Taxpayer�s proper tax accounting treatment of the payments to and from the �experience account� established by the reinsurance contract entered into between Taxpayer and Company Y? |
| 200203015(PDF, 20K) |
1/18/2002 |
| This is in response to your letter, dated June 8, 2001, requesting a private letter ruling that based on your representations, the proposed transaction will qualify for an exception to the general rule of � 367(a)(1) of the Internal Revenue Code of 1986, as amended. Additional information was provided in letters dated August 21, 2001, September 25, 2001, and October 1, 2001. |
| 200203014(PDF, 15K) |
1/18/2002 |
| Issue: Whether Taxpayer�s requested relief under � 7805(b)(8) of the Internal Revenue Code should be granted and TAM 200043017 (July 14, 2000) (TAM) be applied without retroactive effect. |
| 200203013(PDF, 15K) |
1/18/2002 |
| Issue: Whether Taxpayer�s requested relief under � 7805(b)(8) of the Internal Revenue Code should be granted and TAM 200043016 (July 14, 2000) (TAM) be applied without retroactive effect. |
| 200203012(PDF, 12K) |
1/18/2002 |
| Issue: Whether Taxpayer�s requested relief under � 7805(b)(8) of the Internal Revenue Code should be granted and TAM 200043015 (July 14, 2000) (TAM) be applied without retroactive effect. |
| 200203011(PDF, 13K) |
1/18/2002 |
| Issue: Whether Taxpayer�s requested relief under � 7805(b)(8) of the Internal Revenue Code should be granted and TAM 200044005 (July 14, 2000) (TAM) be applied without retroactive effect. |
| 200203010(PDF, 35K) |
1/18/2002 |
| This is in reply to your request for rulings that you are required to include in your gross income a total settlement award of $q paid as a result of your lawsuit against Insured, notwithstanding that a portion of the award, $r, was paid to your attorneys in accordance with a Contingent Fee Agreement and that another portion, $s, was paid to Plaintiff in accordance with a Settlement Agreement, leaving the remainder of the award, $t, to you. You also request that we rule that you are entitled to deduct the payments to your attorneys and Plaintiff as ordinary and necessary trade or business expenses under � 162 of the Internal Revenue Code. Finally, you ask that we rule that the amounts paid to your attorney and Plaintiff are not subject to the alternative minimum tax imposed by � 56. |
| 200203009(PDF, 83K) |
1/18/2002 |
| Issues: (1) Whether tangible personal property used in connection with a hotel/casino complex is includible in asset class 57.0, Distributive Trades and Services, of Rev. Proc. 87-56, 1987-2 C.B. 674, or asset class 79.0, Recreation? (2) Whether various facades, ceilings, wall coverings, millwork, decorative lighting fixtures, kitchen equipment hookups and guest room electrical outlets, emergency power generators, and door locks of the hotel/casino complex are � 1245 property or � 1250 property for depreciation purposes? (3) Whether site utilities at the hotel/casino complex are depreciated as part of the complex or as land improvements? (4) Whether an outdoor pylon sign is depreciated over 15 years as a land improvement? |
| 200203008(PDF, 24K) |
1/18/2002 |
| This letter responds to the request of Taxpayer, dated February 28, 2001, for a 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 July 16, 1999. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200203007(PDF, 36K) |
1/18/2002 |
| Issues: (1) Whether the bankruptcy of a member of a consolidated group causes its partnership items to convert to non-partnership items for non-partner members of the group that have an interest in the items as a result of having been included in the group�s consolidated return. (2) Whether a corporation (�downstream corporation�) that receives substantially all of the former common parent corporation�s assets in a downstream merger becomes the agent for the group for the tax years prior to the merger. 2A. What is the nature and scope of the downstream corporation�s power as agent. (3) Whether the downstream corporation will be considered to have received substantially all of the assets of the former parent, for purposes of Treasury Regulation � 1.1502-75(d)(2)(ii), if a number of the assets of the former parent were conveyed to a shareholder of a few years before the downstream merger. (4) Whether the filing of a bankruptcy petition by the downstream corporation stays the running of the statute of limitations against all members of the old group that are not part of the bankruptcy. 4A. In the event that the automatic stay does not suspend the statute of limitations for the non-bankrupt subsidiaries, does the downstream corporation have the authority to enter into a �Sutton Agreement� for the tax years prior to the merger. |
| 200203006(PDF, 15K) |
1/18/2002 |
| This letter responds to Estate�s request for a private letter ruling, dated May 12, 2000. Specifically, Estate has requested a ruling that interest on bank accounts and dividends on stock held by Decedent should be included in the gross income of Estate in the taxable years in which actually received. |
| 200203005(PDF, 16K) |
1/18/2002 |
| This is in reply to your request for technical assistance to help you with a very difficult full-time life insurance agent case. The firm requested reconsideration of the determination of worker status you issued to one of the firm�s agents. In accordance with Internal Revenue Code � 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200203004(PDF, 30K) |
1/18/2002 |
| Issue: May a commercial airline deduct the estimated incremental cost of transporting passengers in the taxable year a travel voucher is issued and reduce earned revenue by the voucher�s face value less this previously deducted amount in the taxable year the voucher is redeemed for a ticket, or must the airline wait to deduct the actual costs incurred in providing the flight service in the taxable year the flight service is provided? |
| 200203003(PDF, 26K) |
1/18/2002 |
| Issues: (1) Whether Forms 940 and 941c, filed together, constitute a valid return wherein employers frivolously claim exemption from Federal taxes pursuant to Internal Revenue Code � 861. (2) Whether Forms 940 and 941c, filed together, constitute a processible return wherein employers frivolously claim exemption from Federal taxes pursuant to I.R.C. � 861. |
| 200203002(PDF, 24K) |
1/18/2002 |
| Issues: (1) Whether the Service�s Date 4, letter, which informed the Taxpayer that the Service was unable to process his claim for refund based on a net operating loss carryback, constitutes a notice of disallowance pursuant to � 6532(a)(1), thereby starting the period of limitations for filing suit to recover tax. |
| 200203001(PDF, 35K) |
1/18/2002 |
| Issues: (1) Where Taxpayer�s business is selling and leasing equipment, should leased equipment that is also held for sale be treated as "inventory" within the meaning of � 471 of the Internal Revenue Code? (2) Assuming the equipment is not inventory once placed in the leasing operation, under what cInternal Revenue Codeumstances must Taxpayer subsequently treat it as inventory? |
| 200202072(PDF, 24K) |
1/11/2002 |
| This memorandum responds to your brief e-mail dated September 12, 2001, requesting clarification of accepting a taxpayer's prior Form 2555 filed for tax year 1988 as it would affect his � 911 election for 1997. |
| 200202071(PDF, 14K) |
1/11/2002 |
| Issue: What is the legal authority for the signature requirements for the various extension forms? |
| 200202069(PDF, 23K) |
1/11/2002 |
| Issues: (1) What acts trigger the start of the 2-year period of limitations, under � 6532(a)(1) of the Code, for commencing a lawsuit to obtain a refund of an overpayment? (2) Certain versions of Form 4549, Income Tax Examination Changes, do not have any language by which the taxpayer waives the right to a claim disallowance letter; other versions place that language in the "Other Comments" (line 19) area, which is not near the signature line. Under what cInternal Revenue Codeumstances, if any, will the Form 4549 constitute a waiver under � 6532(a)(3) of the taxpayer's right to a notice of claim disallowance? (3) Must the IRS send a notice of deficiency when the EITC is disallowed in whole or in part? If the IRS sends a notice of deficiency and the taxpayer fails to file a timely Tax Court petition, must the IRS then send a notice of claim disallowance in cases in which the taxpayer has not waived the right to a notice of claim disallowance? Will the previously issued notice of deficiency be considered a notice of claim disallowance? (4) What are the proper procedures for handling EITC claims in the following scenarios? |
| 200202068(PDF, 20K) |
1/11/2002 |
| Issue: What should be considered in determining whether a vehicle is excluded from the definition of a highway vehicle by § 48.4061(a)-1(d)(2)(ii) of the Manufacturers and Retailers Excise Tax Regulations (the offhighway vehicle exception)? |
| 200202067(PDF, 12K) |
1/11/2002 |
| Parent 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)-1T(c) 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. |
| 200202066(PDF, 12K) |
1/11/2002 |
| Parent 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)-1T(c) 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. |
| 200202065(PDF, 12K) |
1/11/2002 |
| Requesting rulings on behalf of a group of mutual funds (Funds) as their authorized representative. Each Fund seeks consent to revoke an election previously made under § 4982(e)(4)(A) of the Internal Revenue Code effective for the calendar year 2001 and subsequent years. |
| 200202064(PDF, 5.7K) |
1/11/2002 |
| This letter responds to a letter dated September 03, 2001, submitted on behalf of X by A, X's president, requesting a ruling under §1362(b)(5) of the Internal Revenue Code. |
| 200202062(PDF, 8.1K) |
1/11/2002 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200202061(PDF, 4.7K) |
1/11/2002 |
| This responds to your letter, dated July 16, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200202060(PDF, 21K) |
1/11/2002 |
| This letter responds to your authorized representative�s letter dated October 5, 2001, and subsequent correspondence, submitted on behalf of Taxpayer, requesting a ruling that redemption of the Project's tax-exempt financing at any time after the date on which the Project is placed in service for all purposes under � 42 of the Internal Revenue Code will not, in and of itself, result in a determination that the Project was not
financed by tax-exempt bonds for purposes of � 42(h)(4)(B). |
| 200202059(PDF, 20K) |
1/11/2002 |
| We respond to your request dated July 30, 2001, for rulings about the federal income tax consequences of a proposed transaction. Additional information was provided in a letter dated September 21, 2001. |
| 200202058(PDF, 12K) |
1/11/2002 |
| This letter responds to a letter dated August 13, 2001, submitted on behalf of US Shareholder, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. US Shareholder, as the United States shareholder of Purchaser, the foreign purchasing corporation, is requesting an extension to file a "§ 338 election" under § 338(g) with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date B. (All citations in this letter to regulations under § 338 are to regulations in effect on Date B.) |
| 200202057(PDF, 134K) |
1/11/2002 |
| Issues: (1) Whether FC, in substance, owned the shares of FB stock that were redeemed. (2) If FC is treated as having properly acquired the shares of FB stock that were redeemed, whether FB's redemption of its stock held by FC is an exchange or a distribution to which � 301 applies. (3) If FB's redemption of its stock held by FC is deemed to be a distribution to which � 301 applies, whether TP's adjustment to his basis in FB stock was a "proper adjustment" within § 1.302-2(c) of the Income Tax Regulations. (4) If TP's adjustment to his basis in FB stock was a "proper adjustment", whether TP's stock loss was not a bona fide loss with the result that the purported stock loss is disallowed under � 165. (5) If TP's adjustment to his basis in FB stock was a "proper adjustment," whether TP acquired control of FC with a principal purpose of avoiding or evading Federal income tax with the result that the purported stock loss is disallowed under � 269. |
| 200202056(PDF, 19K) |
1/11/2002 |
| Issues: 1) Whether the transfer of Taxpayer's Year 1 and Year 2 overpayments to Taxpayer's 2 nd quarter Year 9 estimated tax installment constitutes a credit elect under � 6402(b)? 2) Whether the transfer of Taxpayer's overpayments to its 2 nd quarter estimated tax installment on May 15, Year 8 constitutes a credit to an "outstanding tax liability" under � 6402(a)? |
| 200202055(PDF, 8.3K) |
1/11/2002 |
| This written determination is in response to your request on behalf of L.P., dated August 13, 2001, requesting that L.P. be granted an extension of time in which to make an election under � 754 of the Internal Revenue Code. |
| 200202054(PDF, 6.5K) |
1/11/2002 |
| This letter responds to a letter dated August 15, 2001, written on behalf of X, requesting an extension of time under � 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. X is requesting a ruling that it be granted an extension of time in which to elect to treat its wholly owned subsidiary, Y, as a qualified subchapter S subsidiary under � 1361(b)(3) of the Internal Revenue Code. |
| 200202053(PDF, 8.1K) |
1/11/2002 |
| This written determination is in response to your request on behalf of L.P. dated August 6, 2001, requesting that L.P. be given an extension of time in which to make an election under � 754 of the Internal Revenue Code. |
| 200202052(PDF, 7.8K) |
1/11/2002 |
| This responds to your letter dated, August 23, 2001 in which you requested relief 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. |
| 200202051(PDF, 6.5K) |
1/11/2002 |
| This letter responds to your letter dated April 10, 2001, and subsequent correspondence on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200202050(PDF, 18K) |
1/11/2002 |
| 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 April 20, 2001: |
| 200202049(PDF, 12K) |
1/11/2002 |
| Parent (as the common parent of the consolidated group of which Sub, the United States shareholder of Purchaser, the "foreign purchasing corporation" is a member) is requesting an extension to file a "§ 338 election" under § 338(g) with respect to the acquisition of the stock of Target and Target Sub (sometimes hereinafter referred to as the "Election"), on Date A. |
| 200202048(PDF, 27K) |
1/11/2002 |
| This letter is in response to Taxpayer's authorized representative's letter of June 4, 2001, and subsequent correspondence concerning your request for a private letter ruling pertaining to § 45 of the Internal Revenue Code. |
| 200202047(PDF, 23K) |
1/11/2002 |
| We respond to your letter dated April 10, 2001, for rulings concerning the federal income tax consequences of a proposed transaction. |
| 200202046(PDF, 13K) |
1/11/2002 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200202045(PDF, 19K) |
1/11/2002 |
| Issues:The issue presented is whether Taxpayer's contract for soil remediation is a long-term contract subject to Internal Revenue Code � 460 so that Taxpayer is required to use the percentage of completion method (PCM) to report its income from the contract. |
| 200202044(PDF, 13K) |
1/11/2002 |
| This letter responds to a letter dated May 7, 2001, submitted by Target 1 and Target 2 (on behalf of itself and as common parent of a consolidated group). Target 1 and Target 2 are requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations for Target 1 to file an election under § 1.382-8(h) (the "Election"). |
| 200202043(PDF, 13K) |
1/11/2002 |
| This letter responds to a letter dated May 7, 2001, submitted by Target 1 and Target 2 (on behalf of itself and as common parent of a consolidated group). Target 1 and Target 2 are requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations for Target 1 to file an election under § 1.382-8(h) (the "Election"). |
| 200202042(PDF, 5.5K) |
1/11/2002 |
| This letter responds to your letter, dated August 27, 2001, and subsequent correspondence, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200202041(PDF, 6.1K) |
1/11/2002 |
| This letter responds to a letter dated August 29, 2001, together with other correspondence, submitted on behalf of X and requesting a ruling under §1362(b)(5) of the Internal Revenue Code. |
| 200202040(PDF, 6.2K) |
1/11/2002 |
| This letter responds to a letter dated August 14, 2001, submitted on behalf of X by A, X's president, requesting a ruling under §1362(b)(5) of the Internal Revenue Code. |
| 200202039(PDF, 6.4K) |
1/11/2002 |
| This letter responds to your letter dated January 15, 2001, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200202038(PDF, 6.0K) |
1/11/2002 |
| This letter responds to a letter dated June 15, 2001, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200202037(PDF, 6.0K) |
1/11/2002 |
| This letter responds to a letter dated May 14, 2001, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200202036(PDF, 13K) |
1/11/2002 |
| This letter is in response to your letter dated April 2, 2001, requesting a ruling that Taxpayer's disclaimer of her remainder interest in Trust 2 within nine months after learning of her interest in Trust 2 will be made within a reasonable time and will not constitute a taxable gift under § 2501 of the Internal Revenue Code. |
| 200202035(PDF, 24K) |
1/11/2002 |
| Taxpayer is requesting this revised schedule of ruling amounts because a Commission having jurisdiction over Taxpayer's operations has changed the amount included in Taxpayer's cost of service and the date on which the Plant will no longer be included in rate base. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to § 1.468A-3(h)(2). |
| 200202034(PDF, 10K) |
1/11/2002 |
| We are responding to requested ruling number 3, concerning whether Company is entitled to a charitable contribution deduction under § 170 of the Internal Revenue Code upon the exercise by an unrelated charity of an option to purchase Company common stock (the "Option") that the charity acquired from Foundation. |
| 200202033(PDF, 36K) |
1/11/2002 |
| This responds to a letter from your authorized representative dated November 30, 2000, and subsequent correspondence, requesting rulings regarding the income, gift and generation-skipping transfer tax consequences of the division and modification of two trusts. |
| 200202032(PDF, 20K) |
1/11/2002 |
| This letter is in response to your authorized representative's letter dated November 8, 2000, in which a ruling was requested on the federal estate tax consequences of a proposed bequest contribution to Museum. |
| 200202031(PDF, 6.4K) |
1/11/2002 |
| This letter responds to a letter dated May 31, 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. |
| 200202030(PDF, 6.5K) |
1/11/2002 |
| This letter responds to a letter dated June 22, 2001, submitted by your authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200202029(PDF, 5.9K) |
1/11/2002 |
| This letter responds to a letter dated May 21, 2001, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200202028(PDF, 16K) |
1/11/2002 |
| Issues: (1) Whether policy loans on secured by life insurance contracts purchased before June 21, 1986 are to be aggregated with policy loans secured by life insurance contracts purchased after that date for purposes of ascertaining whether the $50,000 loan limit contained in former § 264(a)(4) has been exceeded. (2) If all loans secured by policies insuring the life of a specified individual are aggregated, is the $50,000 limit applied first against the interest that may be disallowed under § 264(a)(4) or first against interest that is not subject to disallowance under that provision. |
| 200202027(PDF, 15K) |
1/11/2002 |
| Requesting a ruling concerning the application of the constructive receipt of income doctrine and � 403(b) of the Internal Revenue Code (the "Code") to the revised paid-time-off (PTO) plan and policy (the "Plan") that E intends to implement for its eligible employees in the near future. |
| 200202026(PDF, 22K) |
1/11/2002 |
| This is to alert all Area Counsel about the attached guidance for examiners issued June 8, 2001, by the Industry Director, Heavy Manufacturing and Transportation regarding the proper tax treatment of cyclical heavy maintenance visits on aInternal Revenue Coderaft airframes. |
| 200202025(PDF, 23K) |
1/11/2002 |
| This letter responds to the request of Taxpayer, dated February 28, 2001, for a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. |
| 200202024(PDF, 7.9K) |
1/11/2002 |
| Requesting an extension of time for Company to elect under § 1361(b)(3)(B) of the Internal Revenue Code to treat Corp as a qualified subchapter S subsidiary (Q Sub). |
| 200202023(PDF, 6.6K) |
1/11/2002 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200202022(PDF, 13K) |
1/11/2002 |
| Issues: (1) Whether A's ownership in certain real property was an interest in a partnership for federal income tax purposes? (2) Whether the taxpayer was entitled to elect to increase the basis in the real property owned as a result of the death of A's wife in Year 1? CONCLUSIONS (1) A's interest in the real property in issue is an interest in partnership for federal tax purposes. (2) Although an election under § 754 of the Internal Revenue Code was not timely filed pursuant to the requirements of § 1.754-1(b) of the Income Tax Regulations for the partnerships in issue, the taxpayer may seek relief from the National Office under § 301.9100 of the Procedure and Administration Regulations. |
| 200202021(PDF, 12K) |
1/11/2002 |
| Issue: Whether amounts attributable to the compaction equipment and top doors of refuse collection vehicles are includable in the tax base for purposes of determining the tax imposed by § 4051(a)(1) of the Internal Revenue Code on Taxpayer's sales of the vehicles. |
| 200202020(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202019(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202018(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202017(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202016(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202015(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202014(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202013(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202012(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202011(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202010(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202009(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202008(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202007(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202006(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202005(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202004(PDF, 11K) |
1/11/2002 |
| This letter responds to a letter dated September 19, 2000, and additional correspondence, written on behalf of Company and X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202003(PDF, 11K) |
1/11/2002 |
| Requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to file an election under § 301.7701-3(c) to be treated as a disregarded entity effective D1. |
| 200202002(PDF, 52K) |
1/11/2002 |
| Issues: (1) Whether the economic family theory set forth in Rev. Rev. 77-316, 1977-2 C.B. 53, applies to prevent the taxpayer from deducting purported insurance premiums paid to a related insurance company? (2) Whether the facts in this case are sufficiently different to distinguish the case from the taxpayer in Humana, Inc. v. Commissioner, 881 F.2d 247 (6 th Cir. 1989)? |
| 200202001(PDF, 16K) |
1/11/2002 |
| Issue: If a taxpayer files an amended return seeking to change his or her marital status from married to single or head of household, what type of supporting documentation should the Service Center require? |
| 200201034(PDF, 5.6K) |
1/4/2002 |
| This responds to a letter dated May 19, 2001, and subsequent correspondence submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200201033(PDF, 23K) |
1/4/2002 |
| This letter responds to the request of Taxpayer, dated February 28, 2001, for a 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 July 16, 1999. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200201032(PDF, 16K) |
1/4/2002 |
| This letter is in response to your letter of Date A requesting rulings as to the federal income tax consequences of a proposed transaction. Additional information was received in letters of Date B, Date C and Date D. The pertinent information submitted is summarized below. |
| 200201031(PDF, 6.7K) |
1/4/2002 |
| This replies to your letter dated February 21, 2001, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the annual certification required under § 1.1503-2(g)(2)(vi) for each of the fiscal tax years ended on Dates 1 and 2 with respect to the dual consolidated losses of Entity. |
| 200201030(PDF, 12K) |
1/4/2002 |
| This letter responds to a letter dated June 11, 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. Parent (as the common parent of the consolidated group of which Sub, the United States shareholder of Purchaser, the "foreign purchasing corporation" is a member) is requesting an extension to file a "§ 338 election" under § 338(g) with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date B. (All citations in this letter to regulations under § 338 are to regulations in effect on Date B.) Additional information was received in letters dated August 16, 2001 and October 5, 2001. |
| 200201029(PDF, 8.5K) |
1/4/2002 |
| This is in response to a letter dated B, by A�s authorized representative, 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. |
| 200201028(PDF, 8.1K) |
1/4/2002 |
| This replies to a letter dated February 27, 2001, from your authorized representative, requesting an extension of time under Treasury Regulation § 301.9100-3 to allow Taxpayer to file, with respect to the dual consolidated losses incurred by Branch for the tax years ended on Dates 1 and 2, as follows: (i) a certification and agreement under § 1.1503- 2A(d)(3); (ii) an election under § 1.1503-2(h)(2)(ii) to replace the certifications and agreements with elections and agreements under § 1.1503-2(g)(2); and (iii) to file the election and agreement required under § 1.1503-2(g)(2) to replace both of the certifications and agreements. |
| 200201027(PDF, 9.2K) |
1/4/2002 |
| This letter responds to a letter, dated May 24, 2001, and subsequent correspondence, submitted by you on behalf of X as its authorized representative, requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200201026(PDF, 12K) |
1/4/2002 |
| This is in reply to your letter of August 8, 2001, requesting a ruling that the reformation of Trust was a qualified reformation for purposes of � 2055(e)(3) of the Internal Revenue Code, and that the present value of the remainder interest in the Trust as reformed will qualify for a Federal estate tax charitable deduction under � 2055(a). |
| 200201025(PDF, 16K) |
1/4/2002 |
| This responds to your letter dated May 30, 2000, requesting a ruling concerning two factors under paragraph 7 of the revised Memorandum of Understanding accompanying the Income Tax Convention between the United States and Country C (the "Country C Treaty"), and under Article 22 (Limitation on Benefits) of the Country C Treaty. |
| 200201024(PDF, 6.1K) |
1/4/2002 |
| This is in reply to a recent letter, submitted by X's authorized representative on behalf of X, requesting a ruling that Y will be treated as a disregarded entity for federal tax purposes. |
| 200201023(PDF, 8.1K) |
1/4/2002 |
| This replies to a letter dated January 12, 2001, in which Taxpayer requests a ruling under Treasury Regulation § 301.9100-3 for an extension of time to request from the Internal Revenue Service the withholding certificate described in § 1.1445-3(c), where the request should have been made on or before 90 days prior to Date A. |
| 200201022(PDF, 133K) |
1/4/2002 |
| Issues: (1) Whether the transactions described below lack economic substance? (2) Alternatively, whether the transactions described below should be recharacterized as a financing? |
| 200201021(PDF, 6.9K) |
1/4/2002 |
| This replies to a letter from your authorized representative, dated December 28, 2000, requesting an extension of time under Treasury Regulation § 301.9100-3 for Taxpayer on behalf of Subsidiary to make the election provided by Internal Revenue Code § 953(d), in accordance with Notice 89-79, 1989-2 C.B. 392, 393, for the taxable year ended on Date A. A separate ruling letter has addressed Taxpayer's request for an extension of time to elect to file a consolidated federal income tax return under § 1.1502-75(a)(1). |
| 200201020(PDF, 27K) |
1/4/2002 |
| This is in reference to your letter dated November 21, 2000, and subsequent correspondence, requesting rulings regarding the effect of the proposed judicial construction of the trust instrument for federal generation-skipping transfer tax purposes. |
| 200201019(PDF, 21K) |
1/4/2002 |
| This letter responds to your May 16, 2001 request for rulings on certain federal income tax consequences of a transaction that was consummated after the date of your request. Additional information was provided in correspondence dated July 25, 2001 and August 8, 2001. |
| 200201018(PDF, 7.8K) |
1/4/2002 |
| This responds to the letter dated July 2, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200201017(PDF, 27K) |
1/4/2002 |
| This is in reference to your letter dated November 21, 2000, and subsequent correspondence, requesting rulings regarding the effect of the proposed judicial construction of the trust instrument for federal generation-skipping transfer tax purposes. |
| 200201016(PDF, 6.0K) |
1/4/2002 |
| This letter responds to a letter dated May 9, 2001, submitted on behalf of X by X's authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200201015(PDF, 13K) |
1/4/2002 |
| In a letter dated March 13, 2000, you requested rulings regarding your purchase of oil and gas properties. |
| 200201014(PDF, 14K) |
1/4/2002 |
| This letter responds to your letters dated April 24, 2001, August 8, 2001, and August 21, 2001, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file the waiver statement under Rev. Proc. 91-71, 1991-2 C.B. 900, with respect to the inclusion of Subsidiary 3 in Parent's consolidated federal income tax return for Year 2 (the "Election"). |
| 200201013(PDF, 9.4K) |
1/4/2002 |
| This is 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, from a taxable year ending X, to a taxable year ending X, effective. The taxpayer has requested that the Form 1128 be considered timely filed under the authority contained in §301.9100-3 of the Procedure and Administration Regulations. |
| 200201012(PDF, 103K) |
1/4/2002 |
| Issues: (1) Whether FC, in substance, owned the shares of FB stock that were redeemed. (2) If FC is treated as having properly acquired the shares of FB stock that were redeemed, whether FB's redemption of its stock held by FC is an exchange or a distribution to which � 301 applies. |
| 200201011(PDF, 4.6K) |
1/4/2002 |
| This responds to a letter dated March 19, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200201010(PDF, 22K) |
1/4/2002 |
| Issues: (1) Whether the Internal Revenue Code § 183(e) election prevents the start or the continuation of the suspension of interest provisions of I.R.C. § 6404(g) until the end of the statute extension provided in I.R.C. § 183(e)(4). (2) Whether the submission of Form 5213, Election to Postpone Determination with Respect to the Presumption that an Activity is Engaged in for Profit, by the taxpayer constitutes the notice required under I.R.C. § 6404. |
| 200201009(PDF, 22K) |
1/4/2002 |
| Issue: Whether, when applying the tax book value method of apportioning interest expense of Temporary Treasury Regulation §1.861-9T(g) for purposes of determining combined taxable income under � 925(a) of the Internal Revenue Code, the value of Parent's inventory should be reduced by advance and progress payments. |
| 200201008(PDF, 21K) |
1/4/2002 |
| Issues: (1) Is the Facility available to serve, on a regular basis, the general public as required by § 142(a)(1) of the Internal Revenue Code and § 1.103-8(a)(2) and § 1.103-8(e)(1)of the Treasury Regulations? (2) Is the Facility a directly related and essential part of the Airport, an airport as defined by § 142(a)(1) and § 1.103-8(e)(2)(ii)(a), servicing aInternal Revenue Coderaft or enabling aInternal Revenue Coderaft to take-off and land? (3) Is the Facility functionally related to the Airport, as defined in § 142(a)(1) and § 1.103-8(a)(3) and § 1.103-8(e)(2)(b)? |
| 200201007(PDF, 12K) |
1/4/2002 |
| This responds to your letter dated January 26, 2001, requesting a ruling on the proper treatment of an exchange, under § 1031 of the Internal Revenue Code, of a Perpetual Conservation Easement (PCE) in real property for a fee interest in other real estate that will also be burdened with PCE upon receipt. |
| 200201006(PDF, 18K) |
1/4/2002 |
| This letter responds to your November 13, 2000 request for rulings on certain aspects of a proposed transaction (the Proposed Transaction). |
| 200201005(PDF, 9.6K) |
1/4/2002 |
| This is in reply to a letter dated November 6, 2000, submitted on behalf of X. |
| 200201004(PDF, 21K) |
1/4/2002 |
| This is in response to your letter, dated December 26, 2000 on behalf of the above referenced taxpayer, requesting rulings concerning the federal income tax consequences of a proposed transaction. |
| 200201003(PDF, 21K) |
1/4/2002 |
| This letter is in response to your authorized representative's letter, dated February 26, 2001, requesting a ruling regarding the automatic allocation of Donor's generation-skipping transfer exemption, pursuant to § 2632 of the Internal Revenue Code. This letter responds to that request. |
| 200201002(PDF, 21K) |
1/4/2002 |
| This letter is in response to your authorized representative's letter, dated February 26, 2001, requesting a ruling regarding the automatic allocation of Donor's generation-skipping transfer exemption, pursuant to § 2632 of the Internal Revenue Code. |
| 200201001(PDF, 11K) |
1/4/2002 |
| This is in response to a letter dated January 4, 2000, and subsequent correspondence requesting rulings concerning the federal tax status of the Fund. Specifically, the letter requested a ruling that the income earned by the Fund is income excluded from gross income under § 115 of the Internal Revenue Code. |
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