1999 Chief Counsel's
Written Determinations
199900000 to 199904999
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.
| 199904033(PDF, 44K) |
1/22/1999 |
| Issue: Whether the Taxpayer incurred a deductible loss on the lapse or abandonment of an option. |
| 199904032(PDF, 33K) |
1/22/1999 |
| This Field Service Advice responds to your memorandum dated May 26, 1998. Field Service Advice is not binding on Examination or Appeals and is not a final case determination. |
| 199904031(PDF, 37K) |
1/22/1999 |
| This Field Service Advice responds to your memorandum dated July 31, 1998. Field Service Advice is not binding on Examination or Appeals and is not a final case determination. |
| 199904030(PDF, 5K) |
1/22/1999 |
| May 7, 1998 ruling request and subsequent correspondence submitted on behalf of X by X's authorized representative requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 199904029(PDF, 17K) |
1/22/1999 |
| July 12, 1998, requesting a letter ruling concerning whether amounts paid by County Y to Taxpayer in connection with the design, construction, and installation of underground power lines are nonshareholder contributions to capital excludable from income under § 118(a) of the Internal Revenue Code. |
| 199904028(PDF, 7K) |
1/22/1999 |
| June 29, 1998, submitted on behalf of X, requesting a ruling that rents received by X will not constitute "passive investment income" within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 199904027(PDF, 22K) |
1/22/1999 |
| December 12, 1997, and additional correspondence, submitted on behalf of the Taxpayer by its authorized representative, requesting rulings under � 29, 702, and 708 of the Internal Revenue Code relating to a facility for producing solid synthetic fuel from coal fines. |
| 199904026(PDF, 5K) |
1/22/1999 |
| Request for a ruling on behalf of Taxpayers that amounts paid to Taxpayers by a foreign wireless telephone service provider for roaming services as described below are not subject to the communications excise tax imposed by §4251 of the Internal Revenue Code. |
| 199904025(PDF, 11K) |
1/22/1999 |
| June 26, 1998, together with subsequent correspondence, submitted on behalf of PRS, requesting a ruling under § 7704(d) of the Internal Revenue Code that income and gains from PRS's activities relating to storing natural gas will constitute "qualifying income." |
| 199904024(PDF, 7K) |
1/22/1999 |
| October 15, 1998, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 199904023(PDF, 13K) |
1/21/1999 |
| May 27, 1998, requesting rulings concerning the application of § 2056A of the Internal Revenue Code. |
| 199904022(PDF, 15K) |
1/22/1999 |
| Request that Y be given an extension of time to elect to be taxed as a corporation for federal tax purposes under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 199904021(PDF, 15K) |
1/22/1999 |
| Request that Y be given an extension of time to elect to be taxed as a corporation for federal tax purposes under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 199904020(PDF, 7K) |
9/10/1999 |
| Request that Y be given an extension of time to elect to be taxed as a corporation for federal tax purposes under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 199904019(PDF, 20K) |
1/22/1999 |
| June 23, 1998, requesting certain rulings on behalf of Corporation. The requested rulings concern whether cold storage warehouses and central refrigeration systems constitute real estate assets for purposes of § 856(c) of the Internal Revenue Code. |
| 199904018(PDF, 16K) |
1/22/1999 |
| Request that Y be given an extension of time to elect to be taxed as a corporation for federal tax purposes under § 301.7701-3(c) of the Procedure and Administration Regulations. |
| 199904017(PDF, 8K) |
1/22/1999 |
| June 19, 1998, and subsequent correspondence, requesting a ruling that W's assumption of Note 1 and Note 2, as well as the release of Y from all obligations thereunder, is not a significant modification under � 1.1001-3 of the Income Tax Regulations and, therefore, will not be treated as a taxable exchange under � 1001 of the Code. |
| 199904016(PDF, 13K) |
1/22/1999 |
| April 9, 1998, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Additional information was received in and with letters dated June 16, and September 10, 1998. |
| 199904015(PDF, 10K) |
1/22/1999 |
| June 9, 1998 letter requesting the Commissioner's determination of the appropriate method of accounting for bad debts under § 1.381(c)(4)-1(d)(1)(i) of the Income Tax Regulations. |
| 199904014(PDF, 25K) |
1/22/1999 |
| Issues: (1) Whether Entity issued registration-required obligations within the meaning of Internal Revenue Code § 163(f)(2)(A). (2) If Entity issued registration-required obligations and did not satisfy the requirements of � 163(f), is Entity liable for the excise tax imposed pursuant to � 4701? |
| 199904013(PDF, 17K) |
1/22/1999 |
| June 29, 1998 requesting rulings on certain federal income tax consequences of a proposed transaction. |
| 199904012(PDF, 28K) |
1/22/1999 |
| Issue: Whether the taxpayer should recognize a taxable gain as a result of a debt for equity swap. |
| 199904011(PDF, 5K) |
1/22/1999 |
| June 19, 1998, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 199904010(PDF, 19K) |
1/22/1999 |
| July 2, 1998 requesting rulings on certain federal income tax consequences of a series of proposed transactions. |
| 199904009(PDF, 19K) |
1/22/1999 |
| June 19, 1998, requesting a ruling on behalf of the Fund. Specifically, you request an extension of time under � 301.9100-3 of the Regulations on Procedure and Administration to make a "relation-back" election under � 1.468B-1(j)(2)(ii) of the Income Tax Regulations. |
| 199904008(PDF, 7K) |
1/21/1999 |
| May 15, 1998 ruling request and subsequent correspondence submitted on behalf of X by C, its Vice President, requesting relief under § 1362(g) of the Internal Revenue Code. |
| 199904007(PDF, 6K) |
1/22/1999 |
| September 8, 1998, written on behalf of Company, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that Company's S corporation status will be effective as of the taxable year beginning D1. |
| 199904006(PDF, 6K) |
1/22/1999 |
| August 21, 1998, submitted by your authorized representative on behalf of Company, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that Company's S corporation status will be effective beginning D1. |
| 199904005(PDF, 8K) |
1/22/1999 |
| July 20, 1998, and subsequent correspondence dated September 23, 1998, written on behalf of Company, requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 199904004(PDF, 12K) |
1/22/1999 |
| Issue: What legal issues and facts should be considered in applying � 149(b)(4)(A) to exempt facility bonds, qualified small issue bonds and student loan bonds issued by the District of Columbia and U.S. possessions? |
| 199904003(PDF, 6K) |
1/22/1999 |
| August 20, 1998, submitted by your authorized representative on behalf of Company, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that Company's S Corporation status will be effective as of the taxable year beginning D1. |
| 199904002(PDF, 12K) |
1/21/1999 |
| Request of Taxpayer, dated March 11, 1998, and supplemental information submitted by your authorized representative for a revised schedule of ruling amounts pursuant to � 1.468A-3(i)(2) of the Income Tax Regulations. The Commission has increased the amount of decommissioning costs for the Plant. |
| 199904001(PDF, 12K) |
1/21/1999 |
| March 23, 1998, and subsequent correspondence, in which rulings were requested concerning the gift, estate, and generation-skipping transfer tax consequences of a partial release of a testamentary special power of appointment. |
| 199903030(PDF, 42K) |
1/4/1999 |
| March 27, 1998, in which you requested assistance in determining the proper tax treatment for the cost of restoring uninsured property damage caused by severe flooding in the Red River Valley of North Dakota and Minnesota in April 1997. |
| 199903029(PDF, 10K) |
1/4/1999 |
| Issues: (1) Whether North Dakota is entitled to charge the Service an additional fee for the filing of the Notice of Federal Tax Lien Form since it has been classified as a "nonstandard" form due to its size. (2) Whether North Dakota can charge for a release form when the Service files a Notice of Federal Tax Lien. |
| 199903028(PDF, 31K) |
1/25/1999 |
| June 18, 1998 in which you request a ruling that premiums received by the Taxpayer on policies of insurance or reinsurance of United States risks are exempt from the insurance excise tax imposed by � 4371 of the Internal Revenue Code of 1986. |
| 199903027(PDF, 14K) |
1/4/1999 |
| October 27, 1997, and subsequent communications submitted on behalf of the Company, a State A corporation that has elected to be taxable as a real estate investment trust (REIT) pursuant to � 856(c)(1) of the Internal Revenue Code. |
| 199903026(PDF, 6K) |
1/4/1999 |
| August 25, 1998, we sent you a corrected page 3 of the ruling that was issued to you on July 6, 1998 (LTR 9840040, PLR-112984-97). Unfortunately, due to an oversight on our part, the correction was not made prior to the public release of the redacted version of the ruling. |
| 199903025(PDF, 14K) |
1/25/1999 |
| July 3, 1997 letter from your authorized representative requesting gift and estate tax rulings with respect to four trusts. |
| 199903024(PDF, 20K) |
1/4/1999 |
| June 5, 1998 letter requesting a ruling that a corporation providing coverage for a manufactured product against mechanical breakdown, beyond the protection afforded by the manufacturer's warranties, will be treated as an insurance company for federal income tax purposes. |
| 199903023(PDF, 10K) |
1/4/1999 |
| September 8, 1998, and subsequent correspondence, written on behalf of X, requesting a ruling that the termination of X's S corporation status was an inadvertent termination under § 1362(f) of the Internal Revenue Code. |
| 199903022(PDF, 7K) |
1/4/1999 |
| August 27, 1998, written on behalf of X, requesting a ruling that X's S corporation status will be effective as of D1. |
| 199903021(PDF, 7K) |
1/4/1999 |
| July 28, 1998, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 199903020(PDF, 23K) |
1/13/1999 |
| Requesting a ruling that the proposed transaction will satisfy the requirements of § 101(a)(2) (B) of the Internal Revenue Code, and therefore, will not affect the application of § 101(a)(1) to policy proceeds that Taxpayers will receive pursuant to a life insurance purchase agreement relating to a second-to-die policy. |
| 199903019(PDF, 16K) |
1/4/1999 |
| June 16, 1998, in which you requested rulings under §§ 2518 and 2055 of the Internal Revenue Code. |
| 199903018(PDF, 13K) |
1/13/1999 |
| June 22, 1998, as well as subsequent correspondence, requesting a ruling under § 1362(f) of the Internal Revenue Code that the termination of Company's S corporation election was inadvertent. |
| 199903017(PDF, 13K) |
1/25/1999 |
| July 9, 1998, together with prior correspondence, submitted on behalf of the Partnership, requesting rulings under §§ 752 and 465 of the Internal Revenue Code regarding the Partnership's incurrence of debt and its use of the debt proceeds to pay some of the Partnership's existing debt obligations. |
| 199903016(PDF, 8K) |
1/25/1999 |
| Requesting a ruling that X's S corporation status will be effective as of D1. This letter is in reply to that request. |
| 199903015(PDF, 16K) |
1/14/1999 |
| Requesting rulings concerning the application of § 2055(e)(3) of the Internal Revenue Code to the proposed reformation of Article THIRD of Decedent's will. |
| 199903014(PDF, 14K) |
12/30/1999 |
| April 3, 1998 request for rulings on certain federal income tax consequences of a proposed transaction. |
| 199903013(PDF, 23K) |
1/25/1999 |
| June 11, 1998, and prior correspondence submitted on behalf of PRS1 and requesting rulings under various � of the Internal Revenue Code. |
| 199903012(PDF, 7K) |
1/14/1999 |
| September 15, 1998, submitted on behalf of X and requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 199903011(PDF, 9K) |
1/13/1999 |
| Requesting that Taxpayer be granted an extension of time under Treasury Regulation § 301.9100-3 to file the elections required by Treas. Reg. § 1.1503-2(g)(2) for the 1994-1996 net operating losses of the foreign-branch operations of Taxpayer's Domestic Subsidiaries listed on Exhibit A, which is incorporated herein by reference. |
| 199903010(PDF, 11K) |
1/25/1999 |
| Requested rulings regarding your purchase of gas properties. The transaction was later modified as described in a letter dated September 30, 1998. |
| 199903009(PDF, 7K) |
1/4/1999 |
| August 18, 1998, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 199903008(PDF, 7K) |
1/4/1999 |
| September 16, 1998, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 199903007(PDF, 7K) |
1/4/1999 |
| June 11, 1998, together with subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 199903006(PDF, 7K) |
1/4/1999 |
| August 3, 1998, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 199903005(PDF, 19K) |
1/4/1999 |
| Requesting a ruling under § 42 of the Internal Revenue Code. You request a ruling regarding the application of § 42(j) to a proposed transfer of bare legal title to certain real property owned by Taxpayer to General Partner. |
| 199903004(PDF, 19K) |
1/4/1999 |
| July 16, 1998, that was submitted on behalf of Agency and Partnership, requesting a letter ruling under § 42(n)(4) of the Internal Revenue Code and § 1.42-13(b) of the Income Tax Regulations to correct an administrative error in an allocation of the low-income housing credit dollar amounts. |
| 199903003(PDF, 7K) |
1/4/1999 |
| September 5, 1998, submitted on behalf of X and requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 199903002(PDF, 7K) |
1/4/1999 |
| October 1, 1998, and prior correspondence submitted on behalf of X. Your letter requested late S election relief for X under § 1362(b)(5) of the Internal Revenue Code. |
| 199903001(PDF, 16K) |
1/14/1999 |
| April 29, 1998 letter and prior correspondence, submitted on your behalf by your authorized representative, in which you request rulings under � 2055 and 664 of the Internal Revenue Code. |
| 199902018(PDF, 19K) |
1/11/1999 |
| Discussion of Giglio/Henthorn Issues in CRLs This responds to your request for advice regarding the extent to which Giglio/Henthorn 1 issues should be identified and discussed in criminal reference letters ("CRLs"). |
| 199902010(PDF, 138K) |
10/15/1998 |
| For a revised schedule of ruling amounts pursuant to � 1.468A-3(i) (2) of the Income Tax Regulations. The Commission has increased the amount of decommissioning costs to be included in Taxpayer's cost of service for ratemaking purposes. |
| 199902009(PDF, 59K) |
10/15/1998 |
| Submitted on behalf of the Funds listed above. You asked for rulings regarding the multiple class distribution system described below. Generally, the requested rulings involve the qualification of each Fund's distributions as dividends and the consequences of each Fund's share conversion features. |
| 199902008(PDF, 178K) |
10/4/1998 |
| Correspondence submitted on behalf of a, & Q, p4, z, a, s, s, a, by their authorized representative, requesting certain rulings regarding the transfer of certain assets to pl. |
| 199902007(PDF, 35K) |
10/19/1998 |
| Request filed on behalf of X (the taxpayer) for permission to change to the deferred expense method of deducting the research and experimental expenditures relating to the development of the projects listed above pursuant to the provisions of § 174(a) (3) of the Internal Revenue Code, beginning with the tax year ended June 30, 1998 (year of change). |
| 199902006(PDF, 43K) |
10/9/1998 |
| This responds to a letter dated February 27, 1998, together with subsequent correspondence, submitted on behalf of X, requesting relief under �.1362(b) (5) of the Internal Revenue Code. |
| 199902005(PDF, 54K) |
10/8/1998 |
| To save substantial Country B taxes, the following transaction is proposed: (i) Newco S3 will form a new Country B company ("Newco BF3") with a cash contribution funded by a cash contribution from Newco. S2 will hold a Nominal Interest in Newco BF3 to qualify Newco BF3 as a limited under Country B law. |
| 199902004(PDF, 33K) |
10/7/1998 |
| Request for rulings on certain federal income tax consequences of a proposed transaction: (i) Target will form a wholly-owned subsidiary ("Target Distribution Subsidiary") to which Target will transfer the unwanted Target assets in exchange for 100 percent of the common stock and 100 percent of the preferred stock of Target Distribution Subsidiary. |
| 199902003(PDF, 46K) |
10/2/1998 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. x is a corporation that elected to be treated as an S corporation under 5 1362 effective for its taxable year beginning on date 1. |
| 199902002(PDF, 64K) |
9/30/1998 |
| Request for a ruling dated March 6, 1998, concerning a nor-qualified deferred compensation agreement (the vUPlan") established by X and adopted by Y, and a trust ("Trust Y") established by Y. |
| 199902001(PDF, 39K) |
9/30/1998 |
| Request for rulings on certain federal income tax consequences of a proposed series of transactions. As soon as practical following receipt of this ruling letter, Parent will undertake the following transactions: (vii) Sub 2 will distribute the stock of Sub 3 to Sub (1) (viii) Sub 1 will distribute the stock of Sub 3 to Parent. |
| 199901036(PDF, 24K) |
1/25/1999 |
| Issue: Whether the TEFRA 1 restriction on assessment prohibits the assessment and collection of tax attributable to the disallowance of a tentative carrybacks claimed under Internal Revenue Code § 6411. |
| 199901035(PDF, 24K) |
9/30/1998 |
| Requesting relief under 5 1362(b)(5) of the Internal Revenue Code. Was incorporated on date (1) A and B, the shareholders of X, intended X to be an S corporation effective date 1, but Form 2553, Election by a Small Business Corporation, was not filed timely. |
| 199901033(PDF, 41K) |
9/15/1998 |
| Requests a ruling on your behalf concerning whether Plan X qualifies as a church plan under � 414(e) of the Internal Revenue Code. |
| 199901032(PDF, 59K) |
9/14/1998 |
| The letter requests rulings that landfill gas produced and sold by LP will qualify for the credit under 5 29 of the Internal Revenue Code. |
| 199901031(PDF, 25K) |
9/14/1998 |
| 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 fiscal year ending October 31, to a calendar year ending December 31. |
| 199901030(PDF, 49K) |
9/13/1998 |
| Requesting advance approval of your grant-making procedures under � 4945(g) of the Internal Revenue Code. |
| 199901029(PDF, 38K) |
9/13/1998 |
| Requested letter rulings on your behalf concerning the income tax treatment of an individual retirement account ("IRA") under � 408(d) of the Internal Revenue Code. |
| 199901028(PDF, 47K) |
9/9/1998 |
| Requesting a private letter ruling concerning the federal income tax consequences of proposed contributions of property to Partnership. The Service has been requested to rule that no gain will be recognized by A, B, C, Q, E, E, or Partnership under 5 721 of the Internal Revenue Code on the transfer of the assets to Partnership. |
| 199901027(PDF, 37K) |
9/9/1998 |
| Request on behalf of City for extensions of time under § 301.9100-l of the Procedure and Administration Regulations to file carryforward elections under 5 146(f) of the Internal Revenue Code. |
| 199901026(PDF, 68K) |
9/9/1998 |
| Ruling on behalf of Taxpayer that amounts paid to Taxpayer by a foreign wireless telephone service provider for roaming services as described below are not subject to the communications excise tax imposed by S4251 of the Internal Revenue Code. |
| 199901025(PDF, 27K) |
9/9/1998 |
| Requesting permission to change her accounting period, for federal income tax purposes, from a fiscal year ending April 30, to a calendar year ending December 31, effective for the tax year beginning May 1. |
| 199901024(PDF, 32K) |
9/8/1998 |
| Request for rulings on the federal income tax consequences of a proposed transaction. Company has made the following representations concerning the proposed transaction: (a) Company and its shareholders each will pay their own expenses, if any, incurred in the proposed transaction. |
| 199901023(PDF, 72K) |
9/8/1998 |
| Rulings are requested on the income and estate tax consequences of a testamentary gift of an interest in a qualified retirement plan to an inter vivos charitable remainder unitrust. |
| 199901022(PDF, 68K) |
9/8/1998 |
| Requesting relief under F, 13:2(b)(5) of the Internal Revenue Code. X was incorporated on date (1) E and B, the shareholders of x, intended X to be an S corporation effective date 1, but Form 2553, Election by a Small Business Corporation, was not filed timely. |
| 199901021(PDF, 47K) |
9/8/1998 |
| Request rulings concerning the estate and generation-skipping transfer tax consequences of the modifications to the trusts described below. You request that we rule as follows: (1) The proposed changes to Trusts A and B will not cause the interest of any beneficiary of the Trusts, including any beneficiary serving as Trustee, to be includible in such beneficiary's gross estate under § 2033. |
| 199901020(PDF, 30K) |
9/7/1998 |
| Requesting that the Service grant X an extension of time under § 301.9100 of the Procedure and Administration Regulations to elect to treat L, M, and x as qualified subchapter S subsidiaries under 5 1361(b) (3) (B) of the Internal Revenue Code. |
| 199901019(PDF, 39K) |
9/9/1998 |
| Requesting relief under § 1362(f) of the Internal Revenue Code, with respect to the termination of X's S corporation election. |
| 199901018(PDF, 34K) |
9/6/1998 |
| Request the following rulings: (1) the Trust will constitute a qualified settlement fund within the meaning of � 1.4688-l of the Income Tax Regulations; (2) the Trust will be taxed on its modified gross income under � 1.4688-2 of the regulations. |
| 199901017(PDF, 50K) |
9/5/1998 |
| Requesting inadvertent termination relief under 5 1362(f) of the Internal Revenue Code. X was formed under a plan of merger effective on u and elected to be treated as an S corporation effective for its taxable year beginning m. |
| 199901016(PDF, 80K) |
9/1/1998 |
| Supplemental information for a revised schedule of ruling amounts in accordance with � 1.468A-3(i) (1) (iii) (2) of the Income Tax Regulations. Taxpayer is requesting a review of the prior schedule of ruling amounts since, pursuant to the Law, the estimated date on which the Plant will no longer be included in Taxpayer's rate base for ratemaking purposes has been revised. |
| 199901015(PDF, 76K) |
9/1/1998 |
| Request of Taxpayer, dated March 12, 1998, and supplemental information for a revised schedule of ruling amounts in accordance with � 1.468A-3(i) (1) (iii) (2) of the Income Tax Regulations. |
| 199901014(PDF, 33K) |
9/1/1998 |
| Requesting a ruling on behalf of County G, Entity E, and Corporation F. This private ruling request concerns the Federal tax consequences of permitting elective plan-to-plan transfers of assets between Deferred Compensation Plans 6 and C (the "Plans") in the cInternal Revenue Codeumstances described below under � 457 of the Internal Revenue Code of 1986. |
| 199901013(PDF, 57K) |
9/30/1998 |
| On behalf of X concerning the income tax consequences of the amended nor-qualified deferred compensation agreement (the "Plan") and a trust agreement (the "Trust") established by X. |
| 199901012(PDF, 29K) |
9/30/1998 |
| Requesting relief under S 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date 1. |
| 199901011(PDF, 47K) |
9/30/1998 |
| Requesting relief under 5 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date 1. |
| 199901010(PDF, 24K) |
9/29/1998 |
| Requesting relief under 5 1362(b)(5) of the Internal Revenue Code. This letter responds to that request. The represented facts are as follows: z was incorporated on date 1. |
| 199901009(PDF, 49K) |
9/29/1998 |
| On behalf of X concerning a nonqualified deferred compensation agreement (the "Plan") and a trust agreement (the "Trust") established to provide benefits for a select group of management employees (the "Participants") of X. |
| 199901008(PDF, 149K) |
9/29/1998 |
| Requesting rulings concerning the federal income tax treatment of certain transactions related to the Taxpayer's dealings in agricultural products (Commodities). |
| 199901007(PDF, 55K) |
9/28/1998 |
| Request for a ruling dated December 27, 1997, on behalf of X concerning a nonqualified deferred compensation agreements (the "Plan") and a trust agreement (the "Trust") established to provide benefits for designated key management employees (the "Participants") of X and any subsidiary or other affiliate of X who adopts the Plan. |
| 199901006(PDF, 73K) |
9/29/1998 |
| Ruling request submitted on behalf of the above named Parent Company ("Parent") and its wholly-owned Subsidiary ("Subsidiary") with respect to the federal income tax consequences, pursuant to � 83, 451, 671, and 677 of the Internal Revenue Code of 1986, of certain transactions occurring under the above identified ("Plan") and related Trust ("Trust"). |
| 199901005(PDF, 236K) |
9/29/1998 |
| Issues: The first issue is whether deductions of Amounts G in fiscal years Year T, U and V, respectively, relating to Taxpayer's COLI contracts should be disallowed because either (1) the amounts claimed as deductions are not interest paid or accrued within the taxable year on indebtedness as required for a deduction under � 163 of the Internal Revenue Code (Code); or (2) the relationship of the debt to the annual premiums due fails to satisfy the "4 out of 7" test of � 264(c)(l) on interest not otherwise disallowed under � 264(a) (4).' We conclude, for the reasons described below, that these deductions should be disallowed. Second, the Taxpayer has requested, under � 7805(b), that the Service limit the retroactive application of any adverse conclusions drawn herein that limit Taxpayer's deductions for the taxable years T, U and V. |
| 199901004(PDF, 204K) |
9/28/1998 |
| Issue: Whether the expenditures incurred by the Taxpayer in connection with the acquisition of Corp C qualify as Start-up expenditures under 9 195(c)(l) of the Internal Revenue Code. |
| 199901003(PDF, 50K) |
9/22/1998 |
| Issue: Does a subsidiary corporation recognize gain on its use of stock and warrants of its parent corporation that it receives from its parent for the purpose of immediately making a taxable acquisition of property pursuant to a plan? |
| 199901002(PDF, 77K) |
9/23/1998 |
| Issue: Whether the subject organization's income from the storage of cars, boats, motor homes, trailers, etc., during the winter months constitute unrelated business income under � 511 and 512 of the Internal Revenue Code. |
| 199901001(PDF, 28K) |
8/7/1998 |
| Issue: Is Taxpayer entitled to retroactive relief, pursuant to § 7805(b) of the Internal Revenue Code, from federal income tax on income earned during the period beginning October 1, 1994, and ending July 20, 1995? |
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