Internal Revenue Bulletins  

May 20, 1991

Internal Revenue Bulletin No. 1991-20

There are no links to the official documents for the years 1989 through 1995. The information below can only be used as help for further research, as there is not enough information here to rely on for official guidance. For that you need to obtain a copy of the complete document.


Rev. Rul. 91-31
Discharge of indebtedness. The reduction of the principal amount of an undersecured nonrecourse debt by the holder of a debt who was not the seller of the property securing the debt results in the realization of discharge of indebtedness income. Rev. Rul. 82-202 amplified.

Rev. Rul. 91-32
Partnership effectively connected income lookthrough. Gain or loss of a foreign partnership from a disposition of an interest in a partnership that conducts a trade or business through a fixed place of business or has a permanent establishment in the U. S. is gain effectively connected with such trade or business (or loss allowable to such gain) or to gain attributable to a permanent establishment (or loss allowable to such gain).

T.D. 8345

Temporary and proposed regulations under section 148 of the Code relate to arbitrage restrictions on tax-exempt bonds.

Proposed regulations under section 103 of the Code relate to reimbursements of previously paid expenditures with tax-exempt bond proceeds. A public hearing for the proposed regulations will be held on August 8, 1991.


Rev. Proc. 91-25
Rev. Procs. 91-1 and 91-2 modified. This procedure modifies Rev. Procs. 91-1 and 91-2 in several respects. Rev. Proc. 91-1 deals with the issuance of rulings, determination letters and closing agreements. Rev. Proc. 91-2 deals with the issuance of technical advice.

Rev. Proc. 91-29
Waiver of section 911 time requirements. This procedure provides a current list of countries to which section 911(d)(4) of the Code applies.

Rev. Proc. 91-30
Automobile owners and lessees. This procedure provides owners and lessees of passenger automobiles with tables detailing the limitations on depreciation deductions for automobiles first placed in service during calendar year 1991 and the amounts to be included in income for automobiles first leased during calendar year 1991.

Del. Order 42 (Rev. 24)
This order clarifies and extends the authority to execute consents fixing the period of limitations on assessment of collection under provisions of the 1939, 1954, and 1956 Internal Revenue Code. Del. Order 42 (Rev. 23) superseded.

Del. Order 209 (Rev. 5)
This order extends the authority to execute consent agreements to extend the period of limitations involving any partnership or S corporation items that have converted to nonpartnership items or nonsubscriber S items due to one or more events as described in section 6231(b)(1)(A) through (D) of the Code as referred to in section 6229(f). Del. Order 209 (Rev. 4) superseded.

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