Internal Revenue Bulletins  

October 31, 1994

Internal Revenue Bulletin No. 1994-44

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INCOME TAX

T.D. 8566
Final regulations under section 168 of the Code relate to general asset accounts under the accelerated cost recovery system.

INTL-64-93
Proposed regulations under sections 871, 881, 1441, 6038, 6038A, and 7701 of the Code relating to conduit financing arrangements. A public hearing will be held on December 16,1994.

Announcement 94-126
Oaklameda Charities, Oakland, CA, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.


ADMINISTRATIVE

Rev. Proc. 94-67
Procedures for Coordinated Examination Program taxpayers to request that the Service enter into a closing agreement under certain circumstances. The procedures may be used to accelerate the resolution of issues with respect to tax years under examination where the issues resolved may also affect tax years that have not yet been examined. Rev. Proc. 68-16 modified.

Rev. Proc. 94-68
Update of Rev. Proc. 85-13. Rules are provided governing the reopening of cases closed after examination in the office of a District Director. Rev. Proc. 85-13 superseded.

Rev. Proc. 94-69
Update of Rev. Proc. 85-26. Special procedures are provided for Coordinated Examination Program taxpayers to show additional tax or make adequate disclosure for purposes of certain penalties. Rev. Proc. 85-26 superseded.

Rev. Proc. 94-70
Change in election. This procedure tells taxpayers how to make a one time change in election under section 936(h) of the Code without the consent of the Commissioner. In addition it extends the filing date for making the change to December 31, 1994. Rev. Proc. 92-68 modified; Notices 87-27, 88-97, 89-82 and Rev. Procs. 89-61, 90-50, 91-53 and 92-68 amplified and clarified.

Announcement 94-127
An updated edition of Publication 908, Tax Information on Bankruptcy (revised September 1994), is now available.


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