| 200304042(PDF, 1.2M) |
11/1/2002 |
| Request for rulings as to the federal income tax consequences of a participation in a proposed joint venture with physicians to operate a cardiac catheterization laboratory. |
| 200304041(PDF, 1.3M) |
11/1/2002 |
| Request for rulings as to the federal income tax consequences of a participation in a proposed joint venture with physicians to operate a cardiac catheterization laboratory. |
| 200304040(PDF, 325K) |
10/31/2002 |
| Request dated concerning the federal income tax treatment, under � 414(h)(2) of the Internal Revenue Code , of certain contributions to Plan X. |
| 200304039(PDF, 360K) |
10/31/2002 |
| Request for a ruling submitted on your behalf by your authorized representative, concerning the federal income tax treatment of a proposed transfer of funds from one individual retirement account into another individual retirement account under � 408 (d) (3) of the Internal Revenue Code. |
| 200304038(PDF, 282K) |
10/29/2002 |
| Request for a ruling submitted on your behalf by your authorized representative, concerning the federal income tax treatment of a proposed transfer of funds from one individual retirement account into another individual retirement account under � 408 (d) (3) of the Internal Revenue Code. |
| 200304037(PDF, 469K) |
10/29/2002 |
| Request rulings under � 408(d) of the Internal Revenue Code. By virtue of the correspondence dated September 23, 2002, our office is not considering the third ruling request contained in your original submission related to � 72(s)(3) of the Code. |
| 200304036(PDF, 527K) |
10/29/2002 |
| Request a private letter ruling that the provision of student-housing will not adversely affect your exempt status under � 501 (c)(3) of the Internal Revenue Code, or your status as an entity which is not a private foundation under � 509 of the Code. In addition, you request a ruling that the renting of available space to students will not result in unrelated business income tax under � 511 through 513. |
| 200304035(PDF, 879K) |
10/28/2002 |
| Requesting advance approval of your grant-making procedures under � 4945(g) of the Internal Revenue Code. You are exempt under � 501 (c)(3) of the Code and have been classified as a private foundation under � 509(a). |
| 200304034(PDF, 710K) |
10/29/2002 |
| Requested a letter ruling concerning the above-named Tax-Sheltered Annuity Program ("Plan X") under � 403(b) of the Internal Revenue Code. |
| 200304033(PDF, 19K) |
1/24/2003 |
| Issues: (1) The Service has encountered situations where a taxpayer will report selfemployment income and related income and self-employment tax liabilities, even though the taxpayer did not actually have any self-employment income. Taxpayers have reported this self-employment income in order to support an unjustified claim for earned income tax credit (EITC) under Internal Revenue Code � 32 in excess of the reported tax liabilities. The Service will often issue a notice of deficiency that disallows the EITC. The Service bases its determination of a deficiency on a lack of substantiation that the taxpayer actually had self-employment income sufficient to support the claim for EITC. After the taxpayer fails to timely petition the notice of deficiency, the taxpayer will sometimes ask the Service to reconsider its claim for EITC. To support its request, the taxpayer provides substantiation that the taxpayer did, in fact, have self-employment income that gives rise to income and self-employment tax liabilities. The Service, however, determines that despite the substantiated selfemployment income, the taxpayer still does not qualify for the EITC because the taxpayer fails some other EITC eligibility criterion. The Service then issues a second notice of deficiency for the tax attributable to the now substantiated self-employment income. You have asked whether � 6404(g) requires the Service to suspend the application of underpayment interest to this later determination of deficiency. (2) Does the answer to the first question change if the taxpayer waives the restrictions on making a second assessment? (3) Does the answer to the first question change if the Service determines that the taxpayer's income exceeded what he reported on his income tax return? |
| 200304032(PDF, 28K) |
1/24/2003 |
| Issue: Whether Forms 1041, by which purported trusts claim refunds in the amount of social security taxes paid by the putative trust�s fiduciary, should be treated as valid returns under Internal Revenue Code � 6011? |
| 200304031(PDF, 16K) |
1/24/2003 |
| Issue: Whether a signed waiver of the restrictions on assessment sent to the Service after the Service initiates deficiency procedures and assesses the tax should be considered a return of the taxpayer for statute of limitations purposes. |
| 200304030(PDF, 13K) |
1/24/2003 |
| *PULLED* |
| 200304029(PDF, 11K) |
1/24/2003 |
| *PULLED* |
| 200304028(PDF, 8K) |
1/24/2003 |
| Requesting that Corp A, B and C (hereinafter collectively referred to as �Taxpayer�) be granted an extension of time under Treasury Regulation � 301.9100-3 to submit a request to enter into a closing agreement pursuant to Rev. Proc. 2002-42. |
| 200304027(PDF, 16K) |
1/24/2003 |
| Requesting an extension of time under �� 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. 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(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. |
| 200304026(PDF, 11K) |
1/24/2003 |
| Requesting a ruling that the rental income received by Company from the Property is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200304025(PDF, 21K) |
1/24/2003 |
| Requesting rulings concerning the partition of Trust, a charitable remainder unitrust, into two separate trusts. |
| 200304024(PDF, 20K) |
1/24/2003 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations and � 2642(g) of the Internal Revenue Code to make allocations of Trustors� generation-skipping transfer tax exemptions to certain transfers to two irrevocable trusts. |
| 200304023(PDF, 17K) |
1/24/2003 |
| Requested rulings regarding the federal income tax consequences of certain transactions. Distributing, a State A corporation, is the common parent of an affiliated group of corporations that files a consolidated federal income tax return. Distributing has issued and outstanding two classes of voting common stock: Distributing Class A Stock and Distributing Class B Stock. |
| 200304022(PDF, 9K) |
1/24/2003 |
| Reg. � 301.9100-3 for an extension of time to satisfy the requirements of � 1.897-2(h) and � 1.1445-5(d)(2) with respect to the liquidation of Corporation X into Taxpayer, as described below. |
| 200304021(PDF, 8K) |
1/24/2003 |
| This replies to a letter dated September 6, 2001, in which Taxpayer requests a ruling under Treasury Regulation � 301.9100-3 for an extension of time to satisfy the requirements of � 1.897-2(h) and � 1.1445-2(c)(3) with respect to the transactions on Dates A and B. |
| 200304020(PDF, 15K) |
1/24/2003 |
| Requesting an extension of time under �� 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. 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 B. |
| 200304019(PDF, 10K) |
1/24/2003 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations for X to elect to be treated as a disregarded entity under � 301.7701-3. |
| 200304018(PDF, 10K) |
1/24/2003 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations for Y to elect to be treated as a disregarded entity under � 301.7701-3. |
| 200304017(PDF, 7K) |
1/24/2003 |
| Requesting relief under �1362(b)(5) of the Internal Revenue Code. |
| 200304016(PDF, 7K) |
1/24/2003 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200304015(PDF, 31K) |
1/24/2003 |
| Request on behalf of the Issuer for a ruling regarding the qualified 501(c)(3) bonds (the �Bonds�) that it proposes to issue to finance a portion of the construction of the Facility. You have requested a ruling that the proceeds of the Bonds may be allocated to University and government use of the Facility. |
| 200304014(PDF, 8K) |
1/24/2003 |
| Requesting relief under �1362(b)(5) of the Internal Revenue Code. |
| 200304013(PDF, 9K) |
1/24/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200304012(PDF, 8K) |
1/24/2003 |
| Requesting relief under �1362(b)(5) of the Internal Revenue Code. |
| 200304011(PDF, 13K) |
1/24/2003 |
| Requesting an extension of time under � 301.9100-1 of the Procedure and Administration Regulations to make an election under � 856(l) of the Internal Revenue Code to treat Company B as a taxable REIT subsidiary of Company A. |
| 200304010(PDF, 7K) |
1/24/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200304009(PDF, 47K) |
1/24/2003 |
| Issue: Whether, in light of Young v. United States, 122 S. Ct. 1036 (2002), a bankruptcy court may apply the principles of equitable tolling to allow a proof of claim filed after the 180- day period set forth in Bankruptcy Code (�B.C.�) � 502(b)(9) when a Chapter 13 bankruptcy proceeding is dismissed and later reinstated prior to the expiration of such 180-day period. |
| 200304008(PDF, 9K) |
1/24/2003 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A�s loss of 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. |
| 200304007(PDF, 9K) |
1/24/2003 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A�s loss of 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. |
| 200304006(PDF, 16K) |
1/24/2003 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to make an election under � 475(f) of the Internal Revenue Code to use the mark-to-market method of accounting for the tax year ending Date 1. |
| 200304005(PDF, 17K) |
1/24/2003 |
| Requesting rulings concerning the following transaction: M is an organization described in � 501(c)(6) of the Internal Revenue Code. N is a wholly-owned subsidiary of M. M�s membership includes businesses with employees and businesses without employees. |
| 200304004(PDF, 17K) |
1/24/2003 |
| Requesting rulings concerning the following transaction: M is an organization described in � 501(c)(6) of the Internal Revenue Code. N is a wholly-owned subsidiary of M. M�s membership includes businesses with employees and businesses without employees. |
| 200304003(PDF, 17K) |
1/24/2003 |
| Requesting rulings concerning the following transaction: M is an organization described in � 501(c)(6) of the Internal Revenue Code. N is a wholly-owned subsidiary of M. M�s membership includes businesses with employees and businesses without employees. |
| 200304002(PDF, 25K) |
1/24/2003 |
| Request for a private letter ruling that the Taxpayer�s travel and entertainment expense reimbursement reporting procedures satisfy the accountable plan requirements of � 62(c) and the substantiation requirements of � 274(d) of the Internal Revenue Code the. |
| 200304001(PDF, 9K) |
1/24/2003 |
| Requesting that Taxpayer be granted an extension of time under Treasury Regulation � 301.9100-3 to file the certification statement described in � 1.1503-2A(d)(3) with respect to the losses incurred by Branch for the tax years ended on Dates 1, 2, 3, 4 and 5; and to file the election and agreement described in � 1.1503-2(g)(2)(i) with respect to the losses incurred by Branch for the tax years ended on Dates 6 and 7. |
| 200303065(PDF, 1.5M) |
10/25/2002 |
| Request concern the unrelated business income tax treatment of certain activities of M under � 511 through 513 of the Internal Revenue Code of 1986, and the proper classification of income generated from the activities for purposes of calculating M's public support under � 509(a)(l) and 170(b)(l)(A)(vi). M has also requested rulings with respect to income it receives from two limited liability companies. |
| 200303064(PDF, 418K) |
10/23/2002 |
| Request concerning the federal income tax treatment of certain pick up contributions, under � 414(h)(2) of the Internal Revenue Code (�Code�), to Plan X. |
| 200303063(PDF, 310K) |
10/23/2002 |
| Requesting approval of a set-aside of x amount of your income under the suitability test of � 4942(g)(2)(B)(i) of the Internal Revenue Code and � 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations. |
| 200303062(PDF, 1.1M) |
10/22/2002 |
| Requested certain rulings on M�s behalf. Rulings concern the unrelated business income tax treatment of certain activities, including M�s acknowledgment in its publications and on its website of sponsoring organizations that provide benefits to M�s members, and the provision of a link from M�s website to such sponsoring organizations� websites. |
| 200303061(PDF, 430K) |
10/21/2002 |
| Request concerning the application of � 4941 of the Internal Revenue Code to B�s payment of compensation to a disqualified person. |
| 200303060(PDF, 527K) |
10/21/2002 |
| Request relief under � 301.9100-3 of the Procedure and Administration Regulations. |
| 200303059(PDF, 12K) |
1/17/2003 |
| 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. |
| 200303058(PDF, 13K) |
1/17/2003 |
| Requesting a ruling concerning the proposed amended and restated deferred compensation plan which C intends to be an eligible deferred compensation plan under � 457(b) of the Internal Revenue Code of 1986, as amended under the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA). C is represented to be a political subdivision of a state described in � 457(e)(1)(A) of the Code. |
| 200303057(PDF, 18K) |
1/17/2003 |
| Requesting rulings as to the federal income tax consequences of a proposed transaction. Fact: Distributing is a State A corporation which incorporated in Year 1 and elected S status effective for Year (2) Distributing has issued and outstanding a shares of common stock which are held equally by b related shareholders. |
| 200303056(PDF, 16K) |
1/17/2003 |
| 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 Original Parent, Parent, Subsidiary1, Subsidiary2, Subsidiary3, Subsidiary4, Subsidiary5, and Subsidiary6 to make a ratable allocation election (�the Election�) under � 1.1502-76(b)(2)(ii) of the Income Tax Regulations. |
| 200303055(PDF, 15K) |
1/17/2003 |
| 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, Subsidiary1, Subsidiary2, Subsidiary3, Subsidiary4, Subsidiary5, Subsidiary6, and Subsidiary7 to make an election to file a consolidated federal income tax return, with Parent as the common parent, under � 1.1502-75(a)(1) (hereinafter referred to as (�the Election�), effective for the taxable year beginning on Date C and ending on Date D (�short year�). |
| 200303054(PDF, 12K) |
1/17/2003 |
| Requesting inadvertent termination relief under � 1362(f) of the Internal Revenue Code. |
| 200303053(PDF, 17K) |
1/17/2003 |
| Requested an extension of time under � 301.9100-3 of the Procedure and Administration Regulations and � 2642(g) of the Internal Revenue Code to allocate Husband�s and Wife�s remaining GST exemption to five pooled income funds. |
| 200303052(PDF, 9K) |
1/17/2003 |
| This letter responds to a letter submitted on April 22, 2002, requesting that the Service grant an extension of time to make an election under � 469(c)(7)(A) of the Internal Revenue Code and � 1.469-9(g)(3) of the Income Tax Regulations to treat all interests in rental real estate as a single real estate activity. |
| 200303051(PDF, 11K) |
1/17/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. The following reflects information contained in that letter and subsequent correspondence. Cooperative is a cooperative company that primarily provides Utility W. Before Year X, Cooperative qualified for tax exemption as an organization described in � 501(c)(12) of the Internal Revenue Code. |
| 200303050(PDF, 15K) |
1/17/2003 |
| Requesting an extension of time under �� 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser is requesting an extension to file a �� 338 election� under � 338(g) with respect to Purchaser�s acquisition of the stock of Target and the deemed acquisition of the stock of Target Subsidiary1 (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.) |
| 200303049(PDF, 8K) |
1/17/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1. A, the president of X, represents that X was intended to be an S corporation effective D1. However, no Form 2553, Election by a Small Business Corporation, was timely filed for X. |
| 200303048(PDF, 8K) |
1/17/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1. A, B, and C are the shareholders of X. A, the president of X, represents that X was intended to be an S corporation effective D1. However, no Form 2553, Election by a Small Business Corporation, was timely filed for X. |
| 200303047(PDF, 9K) |
1/17/2003 |
| Requesting an extension under � 301.9100-3 of the Procedure and Administration Regulations for LLC to elect to be treated as an association taxable as a corporation for federal tax purposes. |
| 200303046(PDF, 11K) |
1/17/2003 |
| Requesting a ruling that X's rental income from Property is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200303045(PDF, 8K) |
1/17/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200303044(PDF, 9K) |
1/17/2003 |
| Requesting a ruling on behalf of Corporation under � 1362(b)(5) of the Internal Revenue Code. |
| 200303043(PDF, 10K) |
1/17/2003 |
| Requesting a ruling that the Service grant Corporation an extension of time pursuant to � 301.9100-3 of the Procedure and Administration Regulations to elect to treat Subsidiary as a qualified subchapter S subsidiary under � 1361(b)(3) of the Internal Revenue Code. |
| 200303042(PDF, 7K) |
1/17/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200303041(PDF, 31K) |
1/17/2003 |
| Request for a ruling on whether State X can properly sponsor a � 403(b) plan, as well as other rulings concerning the status of Trust D as a group trust under � 401(a)(24) of the Code and the proper treatment under � 3402 of the Code of elective contributions made on behalf of participants of Plan A. |
| 200303040(PDF, 14K) |
1/17/2003 |
| Requesting an extension of time under �� 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent and Seller 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(c) of the Income Tax Regulations with respect to Purchaser�s acquisition of the stock of Target on Date A. |
| 200303039(PDF, 9K) |
1/17/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200303038(PDF, 10K) |
1/17/2003 |
| Requesting that the Service grant Partnership an extension of time to make an election under � 754 of the Internal Revenue Code. |
| 200303037(PDF, 11K) |
1/17/2003 |
| Request for 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. |
| 200303036(PDF, 29K) |
1/17/2003 |
| Request that we supplement our letter ruling dated June 27, 2001 (PLR-127793-01) (the �Prior Letter Ruling�). The information submitted in that request and in later correspondence is summarized below. Capitalized terms not defined in this ruling have the meanings originally assigned them in the Prior Letter Ruling. |
| 200303035(PDF, 10K) |
1/17/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200303034(PDF, 34K) |
1/17/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. The information provided indicates that Distributing is an accrual basis, federally chartered corporation. Distributing is a member-owned cooperative engaged in making loans and performing financially related services to, and exercising supervisory authorities over, As operating in District L. Distributing is exempt from Federal income taxation under � 501(c)(1) of the Internal Revenue Code of 1986, as amended. |
| 200303033(PDF, 12K) |
1/17/2003 |
| Requesting relief under � 1362(f) of the Internal Revenue Code. |
| 200303032(PDF, 11K) |
1/17/2003 |
| Requesting rulings under � 1362 of the Internal Revenue Code. |
| 200303031(PDF, 13K) |
1/17/2003 |
| Requesting a ruling that X be granted an extension of time under � 301.9100 of the Procedure and Administration Regulations to file an election under � 1361(b)(3) of the Internal Revenue Code to treat Y as a qualified subchapter S subsidiary and to file an election to treat Z as a disregarded entity for federal income tax purposes. |
| 200303030(PDF, 27K) |
1/17/2003 |
| Requesting rulings under �� 1001, 2501, and 2601 of the Internal Revenue Code. |
| 200303029(PDF, 14K) |
1/17/2003 |
| Request for a letter ruling concerning the availability of the exemption from Medicare tax contained in � 3121(u)(2)(C) of the Internal Revenue Code to certain school district employees after the unification of two school districts to form a new school district. |
| 200303028(PDF, 11K) |
1/17/2003 |
| This letter responds to your request of Date 1 for a ruling concerning the federal income tax consequences of a proposed transaction. |
| 200303027(PDF, 24K) |
1/17/2003 |
| Requesting rulings regarding the income, gift, and generation-skipping transfer tax consequences of the proposed consolidation of certain trusts. |
| 200303026(PDF, 8K) |
1/17/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200303025(PDF, 17K) |
1/17/2003 |
| Requesting a ruling that the Agency is an instrumentality of State, and charitable contributions to Agency are deductible under � 170(c)(1) as contributions to an entity described in � 170(b)(1)(A)(v), and are subject to the 50% charitable deduction limitation. |
| 200303024(PDF, 20K) |
1/17/2003 |
| Requesting a determination that A, the former common parent of a consolidated group that included B, is eligible to make retroactive elections on behalf of B, under Treasury Regulation � 1.1295-3, to treat certain passive foreign investment companies (�PFICs�) as qualified electing funds (�QEFs�) with respect to B. You also requested a determination that A is eligible to make a deemed dividend election on behalf of B for one of these PFICs, pursuant to Treasury Regulation � 1.1291-9. |
| 200303023(PDF, 14K) |
1/17/2003 |
| Regarding the income tax consequences under � 1001 of the Internal Revenue Code of the proposed partition of the Jointly-Owned Property (JOP) into separate parcels. You have requested a ruling that the partition does not constitute a sale, exchange, or other disposition that would cause any of the taxpayers, A, B, C, or T, to recognize any gain or loss under � 1001. |
| 200303022(PDF, 19K) |
1/17/2003 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer tax exemption. This letter responds to your request. |
| 200303021(PDF, 21K) |
1/17/2003 |
| Issue: Whether Taxpayer�s United States dollar basis of FSub shares acquired from Country A shareholders in a tax-free reorganization described in � 368(a)(1)(B) must be determined with reference to the United States dollar/Currency A exchange rates in effect on the dates on which the Country A shareholders acquired their FSub shares in � 351 nonrecognition transactions, or with reference to the exchange rates in effect on the date of the tax-free reorganization when Taxpayer acquired the FSub shares from the Country A shareholders. |
| 200303020(PDF, 32K) |
1/17/2003 |
| Subsequent correspondence, requesting rulings regarding the application of � 2518 of the Internal Revenue Code to certain disclaimers of interests in Decedent�s estate. |
| 200303019(PDF, 64K) |
1/17/2003 |
| Submitted on behalf of Master Fund, Contributing Fund 1, and Contributing Fund 2, by your authorized representative, requesting certain rulings regarding the transfer of certain assets to Master Fund. |
| 200303018(PDF, 64K) |
1/17/2003 |
| Subsequent correspondence submitted on behalf of Master Fund, Contributing Fund 1, and Contributing Fund 2, by your authorized representative, requesting certain rulings regarding the transfer of certain assets to Master Fund. |
| 200303017(PDF, 64K) |
1/17/2003 |
| Subsequent correspondence submitted on behalf of Master Fund, Contributing Fund 1, and Contributing Fund 2, by your authorized representative, requesting certain rulings regarding the transfer of certain assets to Master Fund. |
| 200303016(PDF, 24K) |
1/17/2003 |
| Requested concerning the estate and gift tax consequences of proposed amendments to four trusts and the proposed merger of four trusts into one trust. |
| 200303015(PDF, 13K) |
1/17/2003 |
| Requesting a ruling on whether Taxpayer will be treated as a �nonresident not a citizen of the United States� for estate and gift tax purposes. |
| 200303014(PDF, 6K) |
1/17/2003 |
| In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year. Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending December 31, to a taxable year ending March 31, effective for the tax year beginning January 1, 2002, and ending March 31, 2002. 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. |
| 200303013(PDF, 19K) |
1/17/2003 |
| Requested an extension of time to make a late election to include part of net capital gains from the dispositions of property held for investment in investment income under �� 163(d)(1) and 163(d)(4)(B) of the Internal Revenue Code for year (1) The request to make the late election is based on �� 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations. |
| 200303012(PDF, 28K) |
1/17/2003 |
| Issue: On what date does interest begin to accrue on a deficiency for Year 1 when Taxpayer credits an overpayment shown on its Year 1 return to its Year 2 estimated tax liability and also makes estimated tax payments sufficient to satisfy its estimated tax liability for Year 2, 3, and 4. |
| 200303011(PDF, 11K) |
1/17/2003 |
| Requesting an extension of time pursuant to �301.9100-3(a) of the Procedure and Administration Regulations to comply with the requirements of �1.367(a)-3T(g)(7) with respect to the Transaction that occurred on D1 in the tax year ended on Date A. |
| 200303010(PDF, 19K) |
1/17/2003 |
| Issue: Whether, in determining the fair market value of Series E United States savings bonds for estate tax purposes, the estate should calculate a lack of marketability discount for the income taxes due on the interest that accrued on the bonds from the date of purchase to the date of maturity. |
| 200303009(PDF, 12K) |
1/17/2003 |
| *PULLED* |
| 200303008(PDF, 9K) |
1/17/2003 |
| This is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year. Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending August 31, to a taxable year ending December 31, 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. |
| 200303007(PDF, 9K) |
1/17/2003 |
| This is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year. Requesting permission to change its accounting period, from a taxable year ending August 31, to a taxable year ending December 31, 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. |
| 200303006(PDF, 9K) |
1/17/2003 |
| In reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year. Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending August 31, to a taxable year ending December 31, 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. |
| 200303005(PDF, 9K) |
1/17/2003 |
| Request that we supplement our letter ruling (PLR-130376-00). An earlier supplemental letter ruling (PLR- 126187-02) was issued on May 20, 2002. The earlier letter ruling and supplemental ruling are together referred to as the �Prior Letter Ruling�. Capitalized terms not defined in this ruling have the meanings originally assigned them in the Prior Letter Ruling. |
| 200303004(PDF, 9K) |
1/17/2003 |
| Request that we supplement our letter ruling dated May 29, 2001 (PLR-100633-01) (the �Prior Letter Ruling�). Capitalized terms not defined in this ruling have the meanings originally assigned them in the Prior Letter Ruling. |
| 200303003(PDF, 18K) |
1/17/2003 |
| Request for a ruling submitted on behalf of the Department regarding whether a settlement payment should be treated as wages subject to taxes under the Federal Insurance Contributions Act (FICA) and federal income tax withholding.1 |
| 200303002(PDF, 7K) |
1/17/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200303001(PDF, 50K) |
1/17/2003 |
| Issues: (1) Should Taxpayer have included the adjusted bases of the functionally interdependent components of a unit of real property that was temporarily withdrawn from service for improvement in the accumulated production expenditures (APEs) of such unit to compute the amount of interest that it was required to capitalize under � 263A(f) of the Internal Revenue Code? (2) When is a unit of real property �temporarily withdrawn from service� for purposes of Treasury Regulation � 1.263A-11(e)(1)(ii)? (3) Under the cInternal Revenue Codeumstances of this case, is Taxpayer�s method of determining the adjusted bases of the functionally interdependent components that were withdrawn from service appropriate? |
| 200302052(PDF, 442K) |
10/15/2002 |
| This is in response to a ruling request in which W, parent of X. is seeking certain rulings as more fully set forth below. |
| 200302051(PDF, 304K) |
10/17/2002 |
| Requesting approval of a set-aside of x amount of your income under the suitability test. of � 4942(g)(2)(B)(i) of the Internal Revenue Code and � 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations. |
| 200302050(PDF, 554K) |
10/17/2002 |
| Requested a ruling on behalf of the Trustees of the above- named pension plan regarding the application of � 41 3(b)(7) of the Internal Revenue Code in determining the deductibility of contributions made to the plan for the plan year ending on June 30, |
| 200302049(PDF, 65K) |
10/16/2002 |
| The purpose of this letter is to revoke private letter rulings 199823057, I9991 3034 and 199952090 issued to you in response to a letter ruling request. |
| 200302048(PDF, 653K) |
10/15/2002 |
| Request submitted by your authorized representative concerning � 72, 170,401,402, 408, 664, 1223, and 2522 of the Internal Revenue Code . |
| 200302047(PDF, 605K) |
10/15/2002 |
| Requesting advance approval of your grant-making procedures under � 4945(g) of the Internal Revenue Code. |
| 200302046(PDF, 6K) |
1/10/2003 |
| State University declined to produce records pursuant to the Service�s administrative summons issued under Internal Revenue Code � 7602. The university declined to produce the records because it believed FERPA barred it from doing so unless it received a document styled as an administrative subpoena. FERPA contains an exception to its privacy requirements for records disclosed pursuant to a court order or a �lawfully issued subpoena.� 20 U.S.C. � 1232g(b)(2)(B). |
| 200302045(PDF, 14K) |
1/10/2003 |
| Determine whether partial property tax abatements and exemptions offered to volunteer emergency responders (�volunteers�) by municipalities in the State of Connecticut constitute taxable income to the recipients. Senator Christopher Dodd and Congressman John Larson have introduced legislation, in the Senate1 and the House2, respectively, that would specifically exclude partial property tax exemptions and abatements from income. We have examined the underlying statute and a similar statute allowing property tax abatements for Massachusetts senior citizens in exchange for services. We conclude that the partial abatements and exemptions of property taxes under this program are includible in the gross income of the recipients. |
| 200302044(PDF, 8K) |
10/10/2003 |
| Request for a supplemental ruling with respect to a ruling letter dated February 5, 2001 (PLR-108328-00, LTR 200118045), (the �Prior Letter�). The Prior Letter concerned a proposed transaction under �� 355 and 368 (�Distributions�). |
| 200302043(PDF, 15K) |
1/10/2003 |
| Issue: If the taxpayer sells his right of redemption under state law to a third party, does the federal tax lien filed prior to the sale encumber the right of redemption and the redeemed real property? |
| 200302042(PDF, 10K) |
1/10/2003 |
| Requesting consent for Taxpayer to revoke its predecessors� elections, effective for Taxable Year c, to use the safe harbor method described in Treasury Regulation �1.901-2A(c)(3) in determining the amount of foreign income tax paid or accrued to Country A. |
| 200302041(PDF, 29K) |
1/10/2003 |
| Request 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 April 10, 2001 (which was corrected by letter dated June 7, 2001). Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200302040(PDF, 13K) |
1/10/2003 |
| Requesting rulings on the Federal income tax consequences of a transaction concerning � 1504 of the Internal Revenue Code. |
| 200302039(PDF, 7K) |
1/10/2003 |
| Request, on behalf of X, for a written determination granting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200302038(PDF, 16K) |
1/10/2003 |
| Requesting, an extension of time pursuant to � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make allocations of generation-skipping transfer (�GST�) exemption. |
| 200302037(PDF, 16K) |
1/10/2003 |
| Requesting,an extension of time pursuant to � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make allocations of generation-skipping transfer (�GST�) exemption. |
| 200302036(PDF, 7K) |
1/10/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200302035(PDF, 16K) |
1/10/2003 |
| Requesting, an extension of time pursuant to � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make allocations of generation-skipping transfer (�GST�) exemption. |
| 200302034(PDF, 18K) |
1/10/2003 |
| Requesting relief under � 301.9100-3 of the Procedure and Administration Regulations to make consent dividend elections under � 565 of the Internal Revenue Code and the regulations thereunder. |
| 200302033(PDF, 16K) |
1/10/2003 |
| Requesting, an extension of time pursuant to � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make allocations of generation-skipping transfer (�GST�) exemption. |
| 200302032(PDF, 15K) |
1/10/2003 |
| Requesting a ruling concerning the application of � 403(b), 451(a) and 457 of the Internal Revenue Code to E�s Unused Sick Leave Conversion Plan (the �Plan�) which E intends to implement for its eligible employees in the near future. E is represented to be a school district which is an eligible governmental employer described in � 457(e)(1)(A) of the Code. |
| 200302031(PDF, 12K) |
1/10/2003 |
| Requesting an extension of time under �� 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an election under � 2057(b)(1)(B) of the Internal Revenue Code. |
| 200302030(PDF, 18K) |
1/10/2003 |
| Requesting rulings on the Federal income tax consequences of a proposed transaction. Distributing is a State N corporation that uses the cash method of accounting. Distributing has w shares of voting common stock outstanding which are owned by A (x shares), B (y shares (approximately 0.02 percent), and C, a trust, (z shares). |
| 200302029(PDF, 21K) |
1/10/2003 |
| Request a ruling that the proposed disclaimer will be a qualified disclaimer under � 2518 of the Internal Revenue Code, and that the proposed reformation of Decedent�s testamentary Trust will be a qualified reformation under � 2055(e)(3). |
| 200302028(PDF, 28K) |
1/10/2003 |
| Request 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 April 10, 2001 (which was corrected by letter dated June 7, 2001). Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200302027(PDF, 28K) |
1/10/2003 |
| Request 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 April 10, 2001 (which was corrected by letter dated June 7, 2001). Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200302026(PDF, 12K) |
1/10/2003 |
| Requesting rulings for Company under � 301.7701-3(c) of the Procedure and Administration Regulations (regarding a late entity classification election) and � 1362(b)(5) of the Internal Revenue Code (regarding a late S corporation election). |
| 200302025(PDF, 9K) |
1/10/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200302024(PDF, 7K) |
1/10/2003 |
| This letter responds to a letter, written by your authorized representative on behalf of X, requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200302023(PDF, 33K) |
1/10/2003 |
| Request for a revised schedule of ruling amounts in accordance with � 1.468A-3(i) and 1.468A-6(e)(2)(ii) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200302022(PDF, 13K) |
1/10/2003 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. The information submitted indicates that Holdco 1, Holdco 2, and Parent are State X corporations that are accrual method taxpayers who each file tax returns on a calendar year basis. |
| 200302021(PDF, 33K) |
1/10/2003 |
| Request of Taxpayer, dated, for a revised schedule of ruling amounts in accordance with � 1.468A-3(i) and 1.468A-6(e)(2)(ii) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200302020(PDF, 7K) |
1/10/2003 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200302019(PDF, 9K) |
1/10/2003 |
| 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. |
| 200302018(PDF, 11K) |
1/10/2003 |
| *PULLED* |
| 200302017(PDF, 17K) |
1/10/2003 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of the Generation-Skipping Transfer tax exemption. |
| 200302016(PDF, 13K) |
1/10/2003 |
| Request for advice in the above-referenced case. First, what are the litigation hazards in arguing that an original manufacturer�s warranty cannot be the subject of insurance for income tax purposes, and that premiums for such insurance are therefore not presently deductible? Second, if an original manufacturer�s warranty can be the subject of insurance, what additional facts should be developed in this case to determine whether the purported insurance arrangements should nevertheless be challenged? |
| 200302015(PDF, 16K) |
1/10/2003 |
| Requesting a ruling concerning the possible application of � 457 of the Internal Revenue Code of 1986 to a number of different nonqualified deferred compensation (NQDC) plans maintained by Entity E. Although E is currently a taxable entity, E represents that it expects soon to receive a favorable determination letter from the Internal Revenue Service concerning its taxexempt status under � 501(c)(3) of the Code. |
| 200302014(PDF, 20K) |
1/10/2003 |
| Requesting a ruling on behalf of Taxpayer that, under � 1504(a)(3)(B) of the Internal Revenue Code , the Service waive the general rule of � 1504(a)(3)(A) of the Code with respect to Holding, Sub #2, Sub #3, and the Lower-Tier Subsidiaries. |
| 200302013(PDF, 57K) |
1/10/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the Plants and associated assets and the proper allocation of basis among the assets received by Buyer. |
| 200302012(PDF, 57K) |
1/10/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the Plants and associated assets and the proper allocation of basis among the assets received by Buyer. |
| 200302011(PDF, 57K) |
1/10/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the Plants and associated assets and the proper allocation of basis among the assets received by Buyer. |
| 200302010(PDF, 57K) |
1/10/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the Plants and associated assets and the proper allocation of basis among the assets received by Buyer. |
| 200302009(PDF, 58K) |
1/10/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of the Plants and associated assets and the proper allocation of basis among the assets received by Buyer. |
| 200302008(PDF, 16K) |
1/10/2003 |
| Requesting rulings as to the federal income tax consequences of a proposed transaction. Distributing is an accrual basis State A corporation and the common parent of a consolidated group consisting of Subsidiary 1 and Controlled. Distributing is directly engaged in Business A. Subsidiary 1, a wholly owned of Distributing, is an inactive corporation. Distributing has outstanding a shares of voting common stock, which is equally owned by Shareholder A and Shareholder B. |
| 200302007(PDF, 9K) |
1/10/2003 |
| Requesting an extension of time under � 301.9100-1 of the Procedure and Administration Regulations to make an alternate valuation election under � 2032(a) of the Internal Revenue Code. |
| 200302006(PDF, 13K) |
1/10/2003 |
| Request that their elections under � 855(a) of the Internal Revenue Code to treat dividends distributed after the close of a taxable year as having been paid during that taxable year be considered timely filed pursuant to � 301.9100-3 of the Procedure and Administration Regulations. |
| 200302005(PDF, 20K) |
1/10/2003 |
| Requesting a ruling under � 2055 of the Internal Revenue Code. |
| 200302004(PDF, 20K) |
1/10/2003 |
| This is in response to your letter dated August 22, 2002, and prior correspondence, in which several generation-skipping transfer tax rulings were requested. |
| 200302003(PDF, 7K) |
1/10/2003 |
| Issue: Is Taxpayer the proper person to claim a credit or payment under � 6427(l)(5) of the Internal Revenue Code with respect to undyed diesel fuel sold to the state as described below? |
| 200302002(PDF, 87K) |
1/10/2003 |
| Issues: (1)(a) Under the cInternal Revenue Codeumstances described below, do the intercompany transaction regulations require Parent to defer the deduction of its rate support payments to Subsidiary in Year 1? (1)(b) Under the cInternal Revenue Codeumstances described below, do the intercompany transaction regulations require Subsidiary to accelerate its inclusion of income related to the rate support payments made by Parent in Years 2 and 3? (2) Under the cInternal Revenue Codeumstances described below, is Parent prohibited from changing its treatment of its rate support payments to Subsidiary for Years 1, 2, and 3 without the consent of the Commissioner? |
| 200302001(PDF, 13K) |
1/10/2003 |
| This Chief Counsel Advice responds to your memorandum dated April 16, 2002. In accordance with Internal Revenue Code � 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200301048(PDF, 112K) |
10/11/2002 |
| This is in reply to your recent ruling request in which you requested a modification of Letter Ruling 20020451. |
| 200301047(PDF, 1.5M) |
10/10/2002 |
| Request dated December 7, 2001, as supplemented by letter dated September 16, 2002, concerning Issues under � 61, 419, 419A, 420, 501, 512 and 4976 of the Internal Revenue Code. |
| 200301046(PDF, 431K) |
10/10/2002 |
| Request relief under � 301.9 100-3 of the Procedure and Administration Regulations. The following facts and representations were made in support of your ruling request. |
| 200301045(PDF, 477K) |
10/9/2002 |
| Requested a ruling under � 414(h)(2) of the Internal Revenue Code. The following facts and representations were submitted in connection with your request. |
| 200301044(PDF, 278K) |
10/8/2002 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ended December 31, 2001. This conditional waiver for the plan year ended December 31,2001, has been granted in accordance with � 41 2(d) of the Internal Revenue Code and � 303 of the Employee Retirement Income Security Act of 1974 (ERISA). |
| 200301043(PDF, 173K) |
10/8/2002 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ended December 31, 2001. Granted in accordance with � 412(d) of the Internal Revenue Code and � 303 of the Employee Retirement Income Security Act of 1974 (ERISA). |
| 200301042(PDF, 168K) |
10/8/2002 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan we have granted a conditional waiver of the minimum funding standard for the plan year ended December 31,2001. Granted in accordance with � 412(d) of the Internal Revenue Code and � 303 of the Employee Retirement Income Security Act of 1974 (ERISA). |
| 200301041(PDF, 15K) |
1/3/2003 |
| Request for advice in the above-referenced matter. In accordance with Internal Revenue Code � 6110(k)(3), this Chief Counsel Advice should not be cited as precedent. This writing may contain privileged information. Any unauthorized disclosure of this writing may have an adverse effect on privileges, such as the attorney client privilege. |
| 200301040(PDF, 7K) |
1/3/2003 |
| Request that we supplement our letter ruling dated December 27, 2000 (PLR-115711-00) (the �Prior Letter Ruling�). Capitalized terms not defined in this ruling retain the meanings assigned them in the Prior Letter Ruling. The Prior Letter Ruling addresses certain federal income tax consequences of the proposed distribution of Controlled stock and related transactions (the �Proposed Transaction�). |
| 200301039(PDF, 12K) |
1/3/2003 |
| Requested a ruling that premiums received by the Taxpayer on policies of insurance or reinsurance of U.S. risks are exempt from the insurance excise tax imposed by � 4371 of the Internal Revenue Code of 1986, as amended (�Code�), pursuant to the United States-Ireland income tax convention . |
| 200301038(PDF, 15K) |
1/3/2003 |
| Requesting a ruling under � 1362(f) of the Internal Revenue Code. |
| 200301037(PDF, 15K) |
1/3/2003 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer exemption. |
| 200301036(PDF, 21K) |
1/3/2003 |
| Request for rulings regarding certain federal income tax consequences of a proposed transaction. Distributing was incorporated as a Subchapter �S� corporation in State A on Date (1) Distributing directly conducts Business 1 and Business 2. |
| 200301035(PDF, 15K) |
1/3/2003 |
| Requesting rulings on the federal income tax consequences of proposed transactions. Taxpayer is a State X not-for-profit, nonstock membership corporation, filing a consolidated federal income tax return as a Subchapter C corporation. Taxpayer uses the calendar year as its annual accounting period and the accrual method of accounting. Taxpayer derives its revenues primarily from Business A. |
| 200301034(PDF, 7K) |
1/3/2003 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200301033(PDF, 21K) |
1/3/2003 |
| Requesting rulings concerning the proposed transfer of funds from an insurance reserve fund to a voluntary employees� beneficiary association (VEBA) trust. |
| 200301032(PDF, 30K) |
1/3/2003 |
| Requesting a ruling concerning the application of � 106, 403(b), (451(a)) and 457 of the Internal Revenue Code to E�s Unused Sick Leave Conversion and Early Retirement Benefits Plan (the �Plan�) which E intends to implement for its eligible employees in the near future. E is represented to be a school district which is an eligible governmental employer described in � 457(e)(1)(A) of the Code. |
| 200301031(PDF, 7K) |
1/3/2003 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200301030(PDF, 17K) |
1/3/2003 |
| Requesting rulings concerning the transaction described below. M is an organization described in � 501(c)(6) of the Internal Revenue Code. N is a wholly-owned subsidiary of M. |
| 200301029(PDF, 33K) |
1/3/2003 |
| Requesting rulings concerning the federal income tax consequences of a proposed transaction. Parent, a State X corporation, is a holding company that uses the accrual method of accounting and a calendar year and files a consolidated return with its subsidiaries. |
| 200301028(PDF, 26K) |
1/3/2003 |
| Requesting an extension of time under � 301.9100- 3 of the Procedure and Administration Regulations to make an allocation of generationskipping transfer tax exemption. |
| 200301027(PDF, 28K) |
1/3/2003 |
| Requesting an extension of time under � 301.9100- 3 of the Procedure and Administration Regulations to make allocations of generationskipping transfer tax exemption. |
| 200301026(PDF, 15K) |
1/3/2003 |
| Requested a ruling regarding the federal income tax consequences of proposed transactions. |
| 200301025(PDF, 16K) |
1/3/2003 |
| Requesting a ruling that the income of Council is excludible from gross income under � 115 of the Internal Revenue Code and that charitable contributions to Council are deductible by the donors to the extent provided by � 170(a) of the Code. |
| 200301024(PDF, 15K) |
1/3/2003 |
| Requesting rulings under � 29 of the Internal Revenue Code. |
| 200301023(PDF, 15K) |
1/3/2003 |
| Requesting rulings under � 29 of the Internal Revenue Code. |
| 200301022(PDF, 13K) |
1/3/2003 |
| Requesting a ruling regarding the applicability of � 4976 to the distribution of Taxpayer assets to participating employers. |
| 200301021(PDF, 13K) |
1/3/2003 |
| Requesting an extension of time under �� 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser 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 A. (All citations in this letter to regulations under � 338 are to regulations in effect on Date A.) |
| 200301020(PDF, 29K) |
1/3/2003 |
| Requested rulings concerning the tax consequences of a judicial division and modification of an irrevocable charitable remainder unitrust into two separate and equal successor trusts. |
| 200301019(PDF, 45K) |
1/3/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds and Buyer�s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and related assets and liabilities. |
| 200301018(PDF, 45K) |
1/3/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds and Buyer�s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and related assets and liabilities. |
| 200301017(PDF, 45K) |
1/3/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds and Buyer�s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and related assets and liabilities. |
| 200301016(PDF, 45K) |
1/3/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds and Buyer�s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and related assets and liabilities. |
| 200301015(PDF, 45K) |
1/3/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds and Buyer�s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and related assets and liabilities. |
| 200301014(PDF, 45K) |
1/3/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds and Buyer�s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and related assets and liabilities. |
| 200301013(PDF, 45K) |
1/3/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds and Buyer�s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and related assets and liabilities. |
| 200301012(PDF, 45K) |
1/3/2003 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds and Buyer�s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and related assets and liabilities. |
| 200301011(PDF, 35K) |
1/3/2003 |
| This letter responds to your December 19, 2001 request for rulings regarding certain federal income tax consequences of a proposed transaction. The rulings contained in this letter are based on facts and representations submitted by the taxpayer and accompanied by a penalties of perjury statement executed by an appropriate party. |
| 200301010(PDF, 28K) |
1/3/2003 |
| Requesting a letter ruling concerning whether the transfer of an intertie from Generator to Taxpayer is a nonshareholder contribution to capital excludable from income under � 118(a) of the Internal Revenue Code. |
| 200301009(PDF, 45K) |
1/3/2003 |
| Request that we rule on certain tax consequences of the sale of Plant and related assets and liabilities from the Sellers to Buyer. Specifically, Taxpayer has requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Sellers� qualified nuclear decommissioning funds and Buyer�s qualified nuclear decommissioning funds as well as rulings regarding the proper realization and recognition of gain and loss on the sale of Plant and related assets and liabilities. |
| 200301008(PDF, 14K) |
1/3/2003 |
| Requesting a ruling that the income of Authority is an instrumentality for purposes of � 141 of the Internal Revenue Code. |
| 200301007(PDF, 10K) |
1/3/2003 |
| Requesting a ruling that X be given an extension of time to elect under � 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes. |
| 200301006(PDF, 10K) |
1/3/2003 |
| Requesting a ruling that X be given an extension of time to elect under � 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes. |
| 200301005(PDF, 10K) |
1/3/2003 |
| Requesting a ruling that P be given an extension of time to elect under � 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a partnership for federal tax purposes. |
| 200301004(PDF, 24K) |
1/3/2003 |
| Issue: Whether the transactions are properly characterized as a disguised sale of a partnership interest? |
| 200301003(PDF, 10K) |
1/3/2003 |
| Requesting a ruling that X be given an extension of time to elect under � 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a disregarded entity for federal tax purposes. |
| 200301002(PDF, 10K) |
1/3/2003 |
| Requesting a ruling that P be given an extension of time to elect under � 301.7701-3(c) of the Procedure and Administration Regulations to be classified as a partnership for federal tax purposes. |
| 200301001(PDF, 25K) |
1/3/2003 |
| Requested permission to change taxpayer's accounting period, for federal income tax purposes, from a taxable year ending April 30, to a calendar taxable year ending December 31, effective December 31, ****. |
