2000 Chief Counsel's
Written Determinations
200020000 to 200024999
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.
| 200024058(PDF, 48K) |
6/16/2000 |
| Whether the doctrine of election precludes a taxpayer from amending past years' returns to retroactively elect to value its assets according to their fair market value for purposes of apportioning interest expense under Treasury Regulation � 1.861-9T(g), when the taxpayer originally elected to value the assets under the tax book value method for those years. |
| 200024057(PDF, 155K) |
9/7/2001 |
| This is in response to a ruling request dated November 3, 1999, as supplemented by correspondence dated March 2,2000, submitted on your behalf by your authorized representative, concerning the federal income tax treatment, under � 414(h)(2) of the Internal Revenue Code , of certain contributions to Plan X and Plan Y. |
| 200024056(PDF, 183K) |
9/7/2001 |
| This is in response to your request for a ruling, dated October 22, 1999, submitted by your authorized representative concerning whether distributions from Plan X are in accordance with � 401 (k) of the Internal Revenue Code. |
| 200024055(PDF, 374K) |
9/7/2001 |
| This is in response to M's request for a ruling that it is a qualified State tuition program, operating as a savings program, exempt from federal income tax under � 529 of the Internal Revenue Code (hereafter "Code"). |
| 200024054(PDF, 141K) |
9/7/2001 |
| We have considered your ruling request dated March 12, 1999, in which you requested rulings on the proper treatment of the transfer of the assets of a sub-account under a voluntary employees' beneficiary association to the remainder of the trust fund under � 501(c)(9), 4976(a), 4976(b)(l)(C), 511(a), 512(a)(3)(A), 419,419(A), 419(A)(c), 1 II (a) and 61(a) of the Internal Revenue Code of 1986, as amended . |
| 200024053(PDF, 232K) |
9/7/2001 |
| We have considered your ruling request with regard to the federal income tax consequences of the proposed transfer of assets from X to Y. |
| 200024052(PDF, 304K) |
9/7/2001 |
| This letter responds to the request of V dated July 22.1999 for rulings regarding the establishment and funding of split-interest trusts in compliance with chapter 42 of the Internal Revenue Code. |
| 200024051(PDF, 6.9K) |
6/16/2000 |
| This Technical Assistance responds to your memorandum dated January 18, 2000, requesting advice on the application of Internal Revenue Code § 6501(c)(8). |
| 200024050(PDF, 11K) |
6/16/2000 |
| This letter responds to your letter, dated December 7, 1999, and subsequent correspondence, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200024049(PDF, 25K) |
6/16/2000 |
| This is in response to a letter dated October 1, 1999, and prior correspondence, requesting rulings that X is a political subdivision, contributions to X may be deductible for federal income tax purposes, and X need not file a federal income tax return. |
| 200024048(PDF, 29K) |
6/16/2000 |
| Whether any portion of the amounts expended to acquire two dental x-ray machines purchased by a family practice dentist are eligible for the disabled access credit under � 44 of the Internal Revenue Code. |
| 200024047(PDF, 6.8K) |
6/16/2000 |
| This letter is in reply to a letter from your authorized representatives, dated August 6, 1999, requesting rulings on a transaction completed on Date C and a proposed transaction. |
| 200024046(PDF, 24K) |
6/16/2000 |
| This letter responds to a letter dated December 3, 1999, and subsequent correspondence submitted by X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200024045(PDF, 10K) |
6/16/2000 |
| This letter responds to your February 8, 2000, request for a private letter ruling as to whether Company, a remote subsidiary of Parent 2 as of the date of your request, timely filed its election for possessions corporation status under � 936 and 30A of the Internal Revenue Code pursuant to the cInternal Revenue Codeumstances described below. |
| 200024044(PDF, 9.0K) |
6/16/2000 |
| This responds to your letter dated November 24, 1999, on behalf of Company, requesting a ruling that the income that Company receives from Property will not be passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200024043(PDF, 16K) |
6/16/2000 |
| This responds to a letter dated January 26, 2000, from your authorized representative on behalf of X, requesting relief under § 1362(g) of the Internal Revenue Code. |
| 200024042(PDF, 7.3K) |
6/16/2000 |
| This letter responds to a letter dated December 16, 1999, and subsequent correspondence, that was submitted on behalf of Agency and Partnership, requesting permission 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. |
| 200024041(PDF, 16K) |
6/16/2000 |
| This letter responds to a letter dated November 23, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200024040(PDF, 7.3K) |
6/16/2000 |
| This ruling letter responds to your letter dated February 1, 2000, and subsequent correspondence, submitted on behalf of Partnership requesting a private letter ruling that will waive for the Project the 10-year holding period requirement for existing buildings of § 42(d)(2)(B)(ii) of the Internal Revenue Code, under the authority of the exception for the acquisition of certain federally-assisted buildings provided in § 42(d)(6)(A)(i). |
| 200024039(PDF, 10K) |
6/16/2000 |
| This letter responds to a letter dated August 20, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200024038(PDF, 22K) |
6/16/2000 |
| This is in response to your letter dated September 1, 1998, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's proposed loss of U.S. citizenship (expatriation) will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200024037(PDF, 12K) |
6/16/2000 |
| This letter responds to your request dated September 15, 1999, for rulings as to the federal income tax consequences of a proposed transaction. |
| 200024036(PDF, 11K) |
6/16/2000 |
| This letter responds to your Authorized Representatives' letter dated January 3, 2000, in which you requested rulings under � 355 of the Internal Revenue Code. |
| 200024035(PDF, 13K) |
6/16/2000 |
| This responds to the above referenced search warrant request submitted to our office by District Counsel. Because the target of the investigation is to a certain degree "a representative of the" the Office of the Assistant Chief Counsel (Criminal Tax) is required to review the search warrant application and recommend whether it should be referred to the Tax Division, Department of Justice for final approval. |
| 200024034(PDF, 9.6K) |
6/16/2000 |
| This is in response to a letter dated July 26, 1999 in which you requested a ruling on behalf of Parent that, under § 1504(a)(3)(B) of the Internal Revenue Code (the "Code"), the Service waive the general rule of � 1504(a)(3)(A) of the Code. |
| 200024033(PDF, 23K) |
6/16/2000 |
| This is in response to your letter dated November 25, 1998, 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. |
| 200024032(PDF, 8.7K) |
6/16/2000 |
| This refers to the letter dated November 10, 1999, which requests certain rulings relating to the qualification of a segregated asset account's investment in a regulated investment company for "look-through" treatment under § 817(h)(4) of the Internal Revenue Code and § 1.817-5(f) of the Income Tax Regulations. |
| 200024031(PDF, 7.5K) |
6/16/2000 |
| This responds to your representative's letter dated January 24, 2000, and subsequent correspondence, written on behalf of X, requesting a ruling that X's S corporation status will be effective as of D1. |
| 200024030(PDF, 7.9K) |
6/16/2000 |
| This responds to your letter dated February 4, 2000, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200024029(PDF, 13K) |
6/16/2000 |
| This responds to a letter dated December 30, 1999, together with subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200024028(PDF, 8.3K) |
6/16/2000 |
| We respond to your letter dated December 2, 1999, requesting rulings concerning the federal income tax consequences of a proposed transaction. |
| 200024027(PDF, 8.2K) |
6/16/2000 |
| This responds to the letter dated March 6, 2000, and prior correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200024026(PDF, 8.4K) |
6/16/2000 |
| This letter responds to your letter, dated January 3, 2000, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation election will be effective as of the taxable year beginning D. |
| 200024025(PDF, 12K) |
6/16/2000 |
| This letter responds to a letter dated September 3, 1999, written on behalf of X, requesting an extension of time under § 301.9100-3 of the Procedure and Administrative Regulations to file an election under § 301.7701-3(c). |
| 200024024(PDF, 8.3K) |
6/16/2000 |
| This responds to the letter dated June 15, 1999, submitted on behalf of the Fund, requesting a ruling under § 301.7701 of the Procedure and Administration Regulations that the Fund is a "business entity" eligible to elect its classification for federal income tax purposes. |
| 200024023(PDF, 39K) |
6/16/2000 |
| This responds to the letter dated February 12, 2000, submitted on behalf of Company by your authorized representative, requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations for Company to elect to be treated as a corporation for federal tax purposes. |
| 200024022(PDF, 20K) |
6/16/2000 |
| Attorney's Fees Awards Under the Hyde Amendment and the Equal Access to Justice Act (EAJA) |
| 200024021(PDF, 13K) |
6/16/2000 |
| A filed a request for ruling that was subsequently withdrawn. We understand that A's representative has informed your office that A will be filing an amended federal income tax return for its taxable year ending Date 1 whereby the loss incurred by B will not be utilized to offset the income of another member of the A consolidated return group for that taxable year or for any other taxable year. |
| 200024020(PDF, 19K) |
6/16/2000 |
| This responds to your letter dated February 11, 2000, and subsequent correspondence, written on behalf of X, requesting inadvertent termination relief under � 1362(f) of the Internal Revenue Code. |
| 200024019(PDF, 34K) |
6/16/2000 |
| This is in response to your letter dated February 8, 2000, and prior correspondence, in -2-which you requested rulings concerning the estate and generation-skipping transfer tax consequences of a proposed exercise of a power of appointment. |
| 200024018(PDF, 19K) |
6/16/2000 |
| Whether amounts received by an employee under the Statute are subject to income and employment taxes. |
| 200024017(PDF, 15K) |
6/16/2000 |
| This is in response to your letter dated February 8, 2000, and prior correspondence, in which you requested rulings concerning the estate and generation-skipping transfer tax consequences of a proposed exercise of a power of appointment. |
| 200024016(PDF, 13K) |
6/16/2000 |
| This is in response to your authorized representative's letter, dated August 6, 1999, requesting a ruling under § 2055 of the Internal Revenue Code concerning a proposed transfer to Trust for the benefit of Mosque located in Village, Country. |
| 200024015(PDF, 19K) |
6/16/2000 |
| This is in response to a letter dated August 26, 1999, and subsequent correspondence, in which rulings were requested concerning the federal gift and estate tax consequences of a Court order construing and reforming Trust. |
| 200024014(PDF, 18K) |
6/16/2000 |
| This is in response to your September 28, 1999 letter and prior correspondence in which you requested rulings under � 2055 of the Internal Revenue Code. |
| 200024013(PDF, 18K) |
6/16/2000 |
| We received a letter dated September 30, 1999, from your authorized representative requesting rulings concerning the application of §§ 2041 and 2514 of the Internal Revenue Code to Trust No. 3 referenced above. |
| 200024012(PDF, 18K) |
6/16/2000 |
| We received a letter dated September 30, 1999, from your authorized representative requesting rulings concerning the application of §§ 2041 and 2514 of the Internal Revenue Code to Trust No. 2 referenced above. |
| 200024011(PDF, 18K) |
6/16/2000 |
| We received your letter dated September 30, 1999, requesting rulings concerning the application of §§ 2041 and 2514 of the Internal Revenue Code to the trusts referenced above. |
| 200024010(PDF, 18K) |
6/16/2000 |
| We received a letter dated September 30, 1999, from your authorized representative requesting rulings concerning the application of §§ 2041 and 2514 of the Internal Revenue Code to Trust No. 4 referenced above. |
| 200024009(PDF, 18K) |
6/16/2000 |
| We received a letter dated September 30, 1999, from your authorized representative requesting rulings concerning the application of §§ 2041 and 2514 of the Internal Revenue Code to Trust No. 1 referenced above. |
| 200024008(PDF, 18K) |
6/16/2000 |
| We received your letter dated September 30, 1999, requesting rulings concerning the application of §§ 2041 and 2514 of the Internal Revenue Code to the trusts referenced above. |
| 200024007(PDF, 37K) |
6/16/2000 |
| We received your letter dated September 30, 1999, requesting rulings concerning the application of §§ 2041 and 2514 of the Internal Revenue Code to the trusts referenced above. |
| 200024006(PDF, 12K) |
6/16/2000 |
| Whether the taxpayer's transfer of all of his stock in his controlled corporation (Corp2) to a second corporation (Corp1), controlled by the taxpayer, in exchange for the forgiveness of debt the shareholder owed to the second corporation (Corp1), constitutes a dividend under Internal Revenue Code § 301 pursuant to I.R.C. § 304(a). |
| 200024005(PDF, 61K) |
6/16/2000 |
| This is in response to the submission on your behalf dated November 4, 1999, requesting a ruling under § 2652 of the Internal Revenue Code and § 301.9100-1 of the Procedure and Administration Regulations. |
| 200024004(PDF, 44K) |
6/16/2000 |
| In general, whether X is entitled to amend its federal income tax return for the Year 1 fiscal year to eliminate previously claimed bad debt deductions attributable to loans to Country 1, Country 2, and Country 3. |
| 200024003(PDF, 17K) |
6/16/2000 |
| Whether the amounts purportedly loaned by FC1 to US1 should be respected as debt. Whether US1 is liable for withholding under § 1442 on payments made to FC1. |
| 200024002(PDF, 36K) |
6/16/2000 |
| This letter responds to your November 3, 1999 request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200024001(PDF, 27K) |
6/9/2000 |
| Whether Q's interest in P was liquidated by P or purchased by U. |
| 200023057(PDF, 355K) |
3/20/2000 |
| A ruling was requested on your behalf with respect to the applicability of � 414(e) of the Internal Revenue Code ( Code ). |
| 200023056(PDF, 252K) |
3/16/2000 |
| This is in response to your letter dated November 3, 1999, end subsequent correspondence dated February 16, 2000, requesting certain rulings under � 507, 4941, 4942, and 4945 of the Internal Revenue Code (the Code ). |
| 200023055(PDF, 98K) |
3/15/2000 |
| A ruling 0n your behalf under � 414(e) of the Internal Revenue Code. |
| 200023054(PDF, 462K) |
5/16/2000 |
| Rulings under � 507,4941, 4942, and 4945 of the Internal Revenue Code [the Code]. |
| 200023053(PDF, 360K) |
5/15/2000 |
| 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 ending December 31, 1999. |
| 200023052(PDF, 305K) |
3/10/2000 |
| Issues: (1) The partial dissolution of X and the distribution of Z's surplus funds attributable to the 1993-96 coverage period under P to retirees or their surviving spouses in proportion to the lump sum contribution that each such retiree was required to pay to 3 will not adversely affect the exempt status of X under � 501 (a) and 501 (c)(9) of the Code. (2) The distribution of X's surplus funds attributable to the 1993-96 coverage period under _P to retirees or their surviving spouses in proportion to the lump sum contribution that each such retiree was required to pay to S will be a refund based on the experience of the entire fund within the meaning of � 419A(f)(5)(B)(ii) of the Code and will not affect the status of X as an employee-pay-all plan under � 419A(f)(5)(B). (3) The distribution of X's surplus funds attributable to the 1993-96 coverage period under this ruling to retirees or their surviving spouses in proportion to the lump sum contribution that each such retiree was required to pay to S will not result in unrelated business taxable income within the meaning of � 512(a)(3)(A) of the Code. |
| 200023051(PDF, 399K) |
3/10/2000 |
| A ruling regarding the proposed investment of the assets of certain charitable organizations and nonexempt charitable trusts in investment portfolios. |
| 200023050(PDF, 61K) |
3/10/2000 |
| A ruling request requesting that your proposed grant will be a qualifying distribution under � 4942(g)(l)(A) of the Internal Revenue Code. |
| 200023049(PDF, 29K) |
6/9/2000 |
| How are "personal belongings" defined for purposes of � 1203(b)(1) of the Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 98)? Does this definition include cars, bank accounts, retirement accounts and household goods? |
| 200023048(PDF, 4.6K) |
6/9/2000 |
| Whether the Internal Revenue Service may apply surplus levy proceeds to a tax period not included on the levy where such tax period is a period in which the taxpayer has not received a Collection Due Process Hearing Notice ("CDP Notice"), or whether the Service must refund the surplus proceeds to the taxpayer. |
| 200023047(PDF, 4.7K) |
6/9/2000 |
| This is to notify you that the Internal Revenue Service is reconsidering the applicability of the tax exception in § 48.4061(a)-1(d)(2)(i) of the Manufacturers and Retailers Excise Tax Regulations to trucks on which cranes are installed. |
| 200023046(PDF, 4.7K) |
6/9/2000 |
| This is to notify you that the Internal Revenue Service is reconsidering the applicability of the tax exception in § 48.4061(a)-1(d)(2)(i) of the Manufacturers and Retailers Excise Tax Regulations to trucks on which cranes are installed. |
| 200023045(PDF, 4.7K) |
6/9/2000 |
| This is to notify you that the Internal Revenue Service is reconsidering the applicability of the tax exception in § 48.4061(a)-1(d)(2)(i) of the Manufacturers and Retailers Excise Tax Regulations to trucks on which crane booms are installed. |
| 200023044(PDF, 4.7K) |
6/9/2000 |
| This is to notify you that the Internal Revenue Service is reconsidering the applicability of the tax exception in § 48.4061(a)-1(d)(2)(i) of the Manufacturers and Retailers Excise Tax Regulations to trucks on which cranes are installed. |
| 200023043(PDF, 7.5K) |
6/9/2000 |
| This is to notify you that the Internal Revenue Service is reconsidering the applicability of the tax exception in § 48.4061(a)-1(d)(2)(i) of the Manufacturers and Retailers Excise Tax Regulations to trucks on which cranes are installed. |
| 200023042(PDF, 7.4K) |
6/9/2000 |
| This letter responds to a letter dated November 29, 1999, and subsequent correspondence submitted by X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200023041(PDF, 28K) |
6/9/2000 |
| This letter responds to a letter, dated June 30, 1999, and subsequent correspondence, submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200023040(PDF, 8.9K) |
6/9/2000 |
| This letter responds to your letter dated August 10, 1999, requesting rulings as to certain federal income tax consequences of a proposed transaction. |
| 200023039(PDF, 7.2K) |
6/9/2000 |
| This replies to a letter dated October 25, 1999, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement and certifications described in § 1.1503-2(g)(2)(i) for the losses incurred by Entities for the fiscal year ended on Date A. |
| 200023038(PDF, 7.1K) |
6/9/2000 |
| This letter responds to your letter dated January 25, 2000, submitted by you as X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200023037(PDF, 17K) |
6/9/2000 |
| This letter responds to a letter dated September 1, 1999, and subsequent correspondence submitted by X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200023036(PDF, 12K) |
6/9/2000 |
| This letter responds to a submission from your authorized representative, dated January 7, 2000, requesting rulings under � 7704 of the Code and the regulations thereunder. |
| 200023035(PDF, 8.6K) |
6/9/2000 |
| The Prior Letter Ruling addresses certain federal income tax consequences of a proposed split-off transaction involving Distributing and Controlled. Because certain aspects of this proposed transaction have changed since the letter's issuance, you have asked that we amend the Prior Letter Ruling as follows: |
| 200023034(PDF, 8.4K) |
6/9/2000 |
| This responds to your representative's letter dated December 30, 1999, and subsequent correspondence, written on behalf of X, requesting a ruling that X's S corporation status will be effective as of D1. |
| 200023033(PDF, 6.8K) |
6/9/2000 |
| This responds to the letter dated February 11, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200023032(PDF, 13K) |
6/9/2000 |
| This letter responds to a letter dated November 28, 1999, and subsequent correspondence submitted by you as X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200023031(PDF, 13K) |
6/9/2000 |
| On Date A, you submitted a request for rulings ("Prior Ruling Request") relating, in part, to the distribution of Controlled stock. In the Prior Ruling Request and in accordance with § 4.05(1)(b) of Revenue Procedure 96-30, 1996-1 C.B. 696, 705, it was represented that Controlled had no plan or intention to repurchase shares following the Distribution other than through stock purchases meeting the requirements of § 4.05(1)(b) of Revenue Procedure 96-30. |
| 200023030(PDF, 7.3K) |
6/9/2000 |
| This letter responds to M's request, perfected December 21, 1999, for a ruling under § 691 of the Internal Revenue Code. |
| 200023029(PDF, 7.9K) |
6/9/2000 |
| This letter responds to a letter dated November 24, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200023028(PDF, 7.6K) |
6/9/2000 |
| This responds to a letter dated January 17, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200023027(PDF, 24K) |
6/9/2000 |
| This responds to your letter dated December 22, 1999, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200023026(PDF, 12K) |
6/9/2000 |
| We received your letter dated August 25, 1999, requesting (1) a ruling that the severance of Trust 1 into two separate trusts pursuant to § 26.2654-1 (b)(1) of the Generation Skipping Transfer Tax Regulations will be recognized for GST tax purposes; and (2) an extension of time under § 301.9100 of the Procedure and Administration Regulations to make a reverse Qualified Terminable Interest Property (QTIP) election under § 2652 of the Internal Revenue Code. This letter responds to your request. |
| 200023025(PDF, 29K) |
6/9/2000 |
| This responds to your request dated November 3, 1999, on behalf of the Tax-Free Funds, that the Internal Revenue Service rule on the status of certain exempt-interest dividends in the hands of a Tax-Free Fund. |
| 200023024(PDF, 30K) |
6/9/2000 |
| When, for foreign tax law purposes, a foreign corporation surrenders losses to a related foreign corporation that uses the losses to reduce its foreign tax liability, and no payment is made in exchange, is the surrender treated as a transfer of value for U.S. tax purposes, resulting in a distribution or capital contribution? |
| 200023023(PDF, 20K) |
6/9/2000 |
| This responds to your Authorized Representative's August 23, 1999 letter requesting, on behalf of the above corporations, an extension of time under 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file elections. |
| 200023022(PDF, 9.1K) |
7/1/2000 |
| This is in response to a letter dated October 4, 1999, and subsequent correspondence, requesting a ruling that (1) the income of Taxpayer is excluded from gross income under § 115 of the Internal Revenue Code; (2) Taxpayer qualifies as a wholly owned instrumentality of a state or political subdivision thereof within the meaning of § 3121(b)(7)(F) for purposes of the OASDI portion of the FICA tax; and (3) Taxpayer qualifies as an instrumentality of a state or political subdivision thereof within the meaning of § 3306(c)(7) for purposes of the FUTA tax. |
| 200023021(PDF, 10K) |
6/9/2000 |
| This responds to your request for a ruling dated August 13, 1999, submitted by your authorized representative on behalf of the Funds. The Funds request a ruling on the application of � 852(b)(6) of the Internal Revenue Code of 1986 to the proposed split-off of one of the classes of shares of the Funds to a newly-created fund. |
| 200023020(PDF, 12K) |
6/9/2000 |
| This is in response to your letter dated February 16, 2000, and prior correspondence in which you requested a ruling that a residence, although occasionally occupied by the son of the term holders, who is not a dependent, may still be held in a Qualified Personal Residence Trust (QPRT) within the meaning of § 25.2702-5(c) of the Code. |
| 200023019(PDF, 85K) |
6/9/2000 |
| This letter responds to your September 22, 1999 request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200023018(PDF, 32K) |
6/9/2000 |
| Whether funds received from an agency of the United States to finance a public project that are, in turn, pledged to pay debt service on municipal obligations create an indirect federal guarantee. |
| 200023017(PDF, 21K) |
6/9/2000 |
| This is in reply to a letter dated September 24, 1999, in which rulings are requested as to the federal income tax consequences of a proposed transaction. |
| 200023016(PDF, 51K) |
6/9/2000 |
| Whether the transfer of properties by Corp1, Corp2, and Corp3 to Corp9 on Date2, qualified as a non taxable transaction under Internal Revenue Code § 351. |
| 200023015(PDF, 15K) |
6/9/2000 |
| Is Taxpayer liable for the excise tax imposed on the sale of its automobile truck chassis by § 4051(a)(1)(A) of the Internal Revenue Code because Taxpayer's chassis fail to meet the exception for certain specially designed mobile machinery for nontransportation functions described in § 48.4061(a)-1(d)(2)(i) of the Manufacturers and Retailers Excise Taxes Regulations (mobile machinery exception)? |
| 200023014(PDF, 119K) |
6/9/2000 |
| Which � 482 Treasury Regulations govern the buy-in payment for Taxable Year 3 with regard to US Group's Date 2 cost sharing arrangement. |
| 200023013(PDF, 7.7K) |
6/9/2000 |
| Is the taxpayer primarily liable for the tax imposed by § 4051 of the Internal Revenue Code on the sale and installation of a truck axle when a truck dealer (the taxpayer) that sells a new taxable truck body and installs it on a new customer-owned chassis also installs on the chassis a truck axle that it sells to the customer? |
| 200023012(PDF, 14K) |
6/9/2000 |
| Is the taxpayer liable for the tax imposed by § 4071 of the Internal Revenue Code on its sale of X? |
| 200023011(PDF, 11K) |
6/9/2000 |
| Is the taxpayer liable for the tax imposed by § 4071 of the Internal Revenue Code on its sale of X? |
| 200023010(PDF, 45K) |
6/9/2000 |
| Whether the captive insurance transactions at issue are insurance for federal income tax purposes. |
| 200023009(PDF, 51K) |
6/9/2000 |
| This is in response to your request for technical assistance (teachers) dated October 27, 1999. We are providing an outline of the applicable legal and regulatory provisions as well as responses to your specific questions. |
| 200023008(PDF, 28K) |
6/9/2000 |
| Whether Taxpayer's subsidiary, X, a mortgage guaranty insurer, may increase its unpaid loss reserve upon notification by the insured lender that the loan is in default, or whether it is precluded from increasing its reserve until foreclosure proceedings have been completed. |
| 200023006(PDF, 66K) |
6/9/2000 |
| Whether, in the year at issue, the taxpayer was the common law employer of the workers provided to its clients, taking into consideration the Danielson rule. See Commissioner v. Danielson, 378 F.2d 771, 775 (3d Cir. 1967) cert. denied, 389 U.S. 858 (1967). |
| 200023005(PDF, 39K) |
6/9/2000 |
| Whether the obligation levied upon by the Internal Revenue Service constituted a "fixed and determinable" property right. Whether attorney's fees as well as fees paid for accounting services and expert witnesses incurred in connection with legal services are entitled to priority over the federal tax lien pursuant to Internal Revenue Code § 6323(b)(8). |
| 200023004(PDF, 6.3K) |
6/9/2000 |
| This is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer, requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending D1, to a taxable year ending D2, effective D3. |
| 200023003(PDF, 39K) |
6/9/2000 |
| Does § 1059(e)(1)(A)(ii) of the Internal Revenue Code (numbered § 1059(e)(1))(B) in the taxable year involved in this case) apply to a redemption of all of one class of preferred stock of a corporation, not accompanied by a redemption of the common stock of the corporation, because the redemption is "not pro rata as to all shareholders" although it is pro rata with respect to the class of stock being redeemed? |
| 200023002(PDF, 16K) |
6/9/2000 |
| On what date should A's late payment of rebate, paid for Period #1 (the first computation period), be taken into account for purposes of computing rebate for the final computation period? |
| 200023001(PDF, 8.4K) |
6/9/2000 |
| To whom should income from discharge of the joint indebtedness of husband and wife be allocated on separately filed returns for the year in which the debt was discharged. |
| 200022059(PDF, 218K) |
3/9/2000 |
| Requesting rulings on X's transfer of approximately one-third of its assets to Y pursuant to � 507(b)(2) of the Internal Revenue Code. |
| 200022058(PDF, 180K) |
3/3/2000 |
| This letter constitutes notice that the request of March 1,1999 for waivers of the 100 percent tax under 5 4971(b) of the Internal Revenue Code has been granted for the above-named plan for the plans years ending December 31,1994 through 1998. |
| 200022057(PDF, 562K) |
2/23/2000 |
| This is in response to a letter dated, 1999, in which your authorized representative requested rulings on your behalf under � 414(e) of the Internal Revenue Code. |
| 200022056(PDF, 330K) |
2/29/2000 |
| This letter responds to X's request dated December 30. 1998. as amended, for rulings regarding the exempt status of X and Y under � 501(c)(4) and (3) of the Internal Revenue Code and the unrelated business income tax consequences of X's provision of services to Y. |
| 200022055(PDF, 146K) |
2/29/2000 |
| A ruling request dated May 20, 1999, with respect to a proposed transfer by A of more than 50% of its assets to B. A is a non-exempt charitable trust described in � 4947(a)(l) of the Internal Revenue Code. |
| 200022054(PDF, 313K) |
2/29/2000 |
| A ruling request concerning a proposed transfer of the assets of a tax-exempt private foundation, X (the Foundation ) to four newly-formed non-profit corporations. |
| 200022053(PDF, 290K) |
2/28/2000 |
| This is in reply to your letter of November 5, 1999, requesting a set-aside ruling under � 4942 of the Internal Revenue Code, in connection with a proposed grant. |
| 200022052(PDF, 7.2K) |
6/2/2000 |
| This letter responds to your request dated November 8, 1999 for a supplement to our prior letter ruling dated September 30, 1999 (the "Prior Letter Ruling") issued to the above referenced taxpayer. |
| 200022051(PDF, 31K) |
6/2/2000 |
| This Chief Counsel Advice responds to your memorandum requesting advice regarding the interplay between eligibility for the earned income credit under Internal Revenue Code (Internal Revenue Code) § 32 and net earnings from self-employment under I.R.C. §1402. |
| 200022050(PDF, 30K) |
6/2/2000 |
| This technical assistance request is in response to your request for assistance dated December 15, 1999, regarding the tax treatment of state payments made to individuals and businesses in North Carolina that suffered losses due to the flood damage caused by Hurricane Floyd. |
| 200022049(PDF, 42K) |
6/2/2000 |
| This memorandum responds to your request for Technical Assistance dated January 6, 2000, requesting guidance District Directors may consider in determining whether to consent to requests to revoke possessions corporations' elections under Internal Revenue Code � 936(a). |
| 200022048(PDF, 22K) |
6/2/2000 |
| This responds to your letter dated July 16, 1998, written on behalf of the Band, requesting rulings under � 61, 451, and 671 of the Internal Revenue Code. |
| 200022047(PDF, 36K) |
6/2/2000 |
| This in reply to a letter dated January 13, 2000, seeking the Secretary's consent to revoke, for Year A and subsequent calendar years thereafter, an election previously made be Fund 1, Fund 2 and Fund 3 ("Fund" or "Funds") under � 4982(e)(4)(A) of the Internal Revenue Code of 1986 as amended ("the Code"). |
| 200022046(PDF, 8.2K) |
6/2/2000 |
| This letter responds to your November 5, 1999 request for a private letter ruling, submitted on behalf of X, requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200022045(PDF, 12K) |
6/2/2000 |
| This is in reply to your letter dated October 19, 1999, requesting rulings as to the federal income tax consequences of a proposed transaction. |
| 200022044(PDF, 15K) |
6/2/2000 |
| We reply to your letter dated October 29, 1999, in which you requested rulings as to the federal income tax consequences of a proposed transaction. |
| 200022043(PDF, 9.0K) |
6/2/2000 |
| This letter responds to the letter dated December 10, 1999, submitted on behalf of Company, requesting an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat three subsidiaries as qualified subchapter S subsidiaries (QSubs) under § 1361(b)(3) of the Internal Revenue Code. |
| 200022042(PDF, 13K) |
6/2/2000 |
| This letter responds to Partnership's authorized representative's letter dated September 28, 1999, requesting a private letter ruling pertaining to the low-income housing tax credit under § 42 of the Internal Revenue Code. |
| 200022041(PDF, 6.7K) |
6/2/2000 |
| This responds to a letter dated December 1, 1999, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200022040(PDF, 9.6K) |
6/2/2000 |
| This responds to your letter, dated December 17, 1999, submitted on behalf of X requesting an extension of time for X to make an election under § 754 of the Internal Revenue Code. |
| 200022039(PDF, 39K) |
6/2/2000 |
| This letter is in reply to a letter from your authorized representatives, dated September 23, 1999, requesting rulings on a proposed transaction. |
| 200022038(PDF, 11K) |
6/2/2000 |
| This letter is in response to your ruling request concerning the use of proceeds of tax-exempt bonds to finance the purchase of certain residential mortgage loans. |
| 200022037(PDF, 8.3K) |
6/2/2000 |
| This responds to your letter dated June 9, 1999, together with subsequent correspondence, submitted on behalf of X requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200022036(PDF, 11K) |
6/2/2000 |
| This responds to your Authorized Representative's letter dated December 2, 1999 requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200022035(PDF, 10K) |
6/2/2000 |
| This is in reply to your letter, dated August 13, 1999, and subsequent correspondence, submitted on behalf of Trust 2 requesting various rulings concerning whether and to what extent B will be treated as the owner of Trust 2 under § 678 of the Internal Revenue Code. |
| 200022034(PDF, 8.2K) |
6/2/2000 |
| This is in reply to a letter of September 21,1999, from your authorized representative, seeking rulings on the reinvestment of proceeds under § 1033 of the Internal Revenue Code. |
| 200022033(PDF, 16K) |
6/2/2000 |
| This responds to a letter from your authorized representative requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file an election under § 1.1502-75 (a)(1) of the Income Tax regulations (hereinafter referred to as "the Election"). |
| 200022032(PDF, 18K) |
6/2/2000 |
| This is in response to your authorized representative's letter dated June 24, 1999, requesting rulings under § 355 of the Internal Revenue Code (the "Code") with respect to a proposed transaction. |
| 200022031(PDF, 16K) |
6/2/2000 |
| This is in reply to the letter from your authorized representative dated January 28, 2000, and prior correspondence requesting a ruling concerning the gift tax treatment of a proposed non-qualified disclaimer of an income interest in a qualified terminable interest property trust. |
| 200022030(PDF, 10K) |
6/2/2000 |
| This is in response to a letter dated June 3, 1998, 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. |
| 200022029(PDF, 8.4K) |
6/2/2000 |
| This is in reply to a letter of September 21, 1999, from your authorized representative, seeking rulings on the reinvestment of proceeds under § 1033 of the Internal Revenue Code. |
| 200022028(PDF, 22K) |
6/2/2000 |
| This is in response to your request for rulings on behalf of the Corporation that (1) any income derived by the Corporation as a result of its proposed activities, as further described below, will be excludable from gross income under § 115 of the Internal Revenue Code, (2) the Bonds to be issued by the Corporation will be considered as issued on behalf of the State under § 103, and (3) the Corporation is an instrumentality of the State under § 141. |
| 200022027(PDF, 9.4K) |
6/2/2000 |
| This responds to your letter dated January 17, 2000, written on behalf of X, requesting a ruling that X be given an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as a corporation for federal tax purposes for its taxable year beginning D1. |
| 200022026(PDF, 7.8K) |
6/2/2000 |
| This responds to your letter dated December 29, 1999, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200022025(PDF, 8.2K) |
6/2/2000 |
| In the Prior Letter Ruling, we issued a favorable ruling under § 355 allowing Distributing to separate its Business A and Business B subsidiaries. |
| 200022024(PDF, 7.3K) |
6/2/2000 |
| This letter responds to a letter dated March 18, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200022023(PDF, 7.3K) |
6/2/2000 |
| This letter responds to a letter dated November 17, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200022022(PDF, 7.4K) |
6/2/2000 |
| This responds to your letter dated December 15, 1999, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200022021(PDF, 9.5K) |
6/2/2000 |
| This responds to your letter dated January 17, 2000, written on behalf of X, requesting a ruling that X be given an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as a corporation for federal tax purposes for its taxable year beginning D1. |
| 200022020(PDF, 13K) |
6/2/2000 |
| We respond to your letter dated November 5, 1999, requesting rulings concerning the federal income tax consequences of a proposed transaction. |
| 200022019(PDF, 11K) |
6/2/2000 |
| This is in response to a letter dated September 17, 1999, and subsequent correspondence, requesting a ruling concerning the exclusion of income of Trust from gross income under § 115 of the Internal Revenue Code. |
| 200022018(PDF, 23K) |
6/2/2000 |
| This letter responds to Taxpayer's request for a private letter ruling, dated December 16, 1998, regarding the federal income tax consequences of the trusts established by the Taxpayer under §§ 61, 671, 675, and 677 of the Internal Revenue Code. |
| 200022017(PDF, 24K) |
6/2/2000 |
| This is to notify you, in accordance with § 8.07(2)(a) of Rev. Proc. 2000-1, 2000-1 I.R.B. 4, 33, that Taxpayer has withdrawn its application for a change in accounting method. |
| 200022016(PDF, 11K) |
6/2/2000 |
| This responds to your letter dated June 30, 1999, submitted on behalf of X, requesting rulings on the federal income tax consequences of the conversion of X from a general partnership to a limited liability company. |
| 200022015(PDF, 22K) |
6/2/2000 |
| This letter responds to your representative's October 31, 1999, request for rulings under § 368 (a)(1)(C) of the Internal Revenue Code (the "Code") on behalf of the above-captioned taxpayers. |
| 200022014(PDF, 13K) |
6/2/2000 |
| This responds to your letter dated August 10, 1999, submitted on behalf of Trust and A, requesting rulings under §§ 664 and 170 of the Internal Revenue Code. |
| 200022013(PDF, 8.0K) |
6/2/2000 |
| This letter responds to your letter, dated August 26, 1999, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation election will be effective as of the taxable year beginning D. |
| 200022012(PDF, 28K) |
6/2/2000 |
| Whether there is a real or potential conflict of interest on the part of A by virtue of A's association with B? Whether and when we need to notify B that B may be called as a witness in the case? |
| 200022011(PDF, 15K) |
6/2/2000 |
| Whether the described containers are portable bait containers taxable as sport fishing equipment under § 4161 of the Internal Revenue Code. |
| 200022010(PDF, 43K) |
6/2/2000 |
| Suspension of Collection Limitation Period During Chapter 11 Bankruptcy Plan |
| 200022009(PDF, 39K) |
6/2/2000 |
| Whether Target Subsidiaries 1 and 2 were required to recapture all of their bad debt reserves in computing the Internal Revenue Code § 481(a) adjustments necessitated by a change in accounting method in connection with a � 381(a)(2) transaction. |
| 200022008(PDF, 15K) |
6/2/2000 |
| We respond to your September 15, 1999 request for rulings regarding certain federal income tax consequences of a proposed transaction. |
| 200022007(PDF, 10K) |
6/2/2000 |
| In computing the Taxpayer's self-employment tax, is the Taxpayer allowed to claim depreciation deductions on a vessel the basis of which has been reduced to zero by reason of � 7518(f) of the Internal Revenue Code? |
| 200022006(PDF, 38K) |
6/2/2000 |
| Whether Taxpayer has gain from restoration of an excess loss account ("ELA") or whether such gain is avoided through use of an intervening � 355 reorganization. |
| 200022005(PDF, 38K) |
6/2/2000 |
| Whether excise and transfer taxes would be applicable if the corpus of C were invaded to pay the personal tax liability of T. Whether the Service's self-imposed administrative stay of collection prohibits the Department of Justice from foreclosing the tax lien in the absence of jeopardy. |
| 200022004(PDF, 63K) |
6/2/2000 |
| Whether a payment in settlement of a claim for back pay by a federal employee is subject to the employee's election to participate in the Federal Thrift Plan, and requires employer matching contributions. |
| 200022003(PDF, 40K) |
6/2/2000 |
| This is in response to your June 18, 1999 letter requesting a series of rulings regarding: the tax status of certain amounts received on death pursuant to Rider 1; the status of certain charges as distributions includible in Taxpayer's gross income under § 72(e)1; and whether the exchange of Taxpayer's existing deferred annuity contract will be treated as an exchange described in § 1035(a)(3). |
| 200022002(PDF, 9.7K) |
6/2/2000 |
| Whether an automobile truck body sold by the taxpayer is subject to the retailers tax on sales of truck bodies imposed by § 4051 of the Internal Revenue Code? |
| 200022001(PDF, 12K) |
6/2/2000 |
| In determining Taxpayer's adjusted ordinary gross income for purposes of determining whether Taxpayer is a personal holding company under § 542(a) of the Internal Revenue Code, are the costs of farm production subtracted from Taxpayer's gross receipts from farming? |
| 200021063(PDF, 247K) |
3/3/2000 |
| In correspondence dated July 30, 1999, your authorized representatives requested a ruling on your behalf that the employee benefit plans maintained by Entity G qualify as church plans under � 4 14(e) of the Internal Revenue Code. |
| 200021062(PDF, 211K) |
3/3/2000 |
| A ruling on your behalf that the employee benefit plan maintained by Entity C, a State N nonprofit corporation, qualifies as a church plan under � 414(e) of the Internal Revenue Code. |
| 200021061(PDF, 193K) |
3/1/2000 |
| This is in response to a ruling request dated September 24, 1999, concerning the pick up of certain employee contributions to Plan X under � 414(h)(2) of the Internal Revenue Code. |
| 200021060(PDF, 222K) |
2/28/2000 |
| A ruling regarding the federal income tax treatment of certain contributions to Plan X under � 414(h)(2) of the Internal Revenue Code. |
| 200021059(PDF, 446K) |
2/29/2000 |
| A ruling regarding the federal income tax treatment of certain contributions to Plan X under � 414(h)(Z) of the Internal Revenue Code . |
| 200021058(PDF, 873K) |
2/28/2000 |
| Ruling concerning the federal income tax treatment, under � 414(h)(2) of the Internal Revenue Code ( Code ), of certain contributions to Plan X. |
| 200021057(PDF, 224K) |
2/28/2000 |
| This is in reply to your rulings request of July 26, 1999, as modified by your letter of February 22, 2000, on T's proposed transfer of all of its assets to C pursuant to � 507(b)(2) of the Internal Revenue Code. |
| 200021056(PDF, 406K) |
2/8/2000 |
| Issues: (1) Whether the operation of a tea room and a gift shop represents a substantial nonexempt purpose that would cause a revocation of M's exempt status under � 501(c)(3) of the Internal Revenue Code. (2) If not, whether income earned by M from the operation of the tea room and gift shop is unrelated business income under � 511 through 513 of the Code. |
| 200021055(PDF, 6.4K) |
5/26/2000 |
| This replies to a letter dated September 2, 1999, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement and certifications described in § 1.1503-2(g)(2) for the losses incurred by Entity for the tax year ended on Date A. |
| 200021054(PDF, 6.9K) |
5/26/2000 |
| This letter responds to a letter, dated January 7, 2000, and subsequent correspondence, submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200021053(PDF, 7.1K) |
5/26/2000 |
| This letter responds to your letter, dated October 9, 1999, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200021052(PDF, 7.0K) |
5/26/2000 |
| This letter responds to your letter dated November 29, 1999, and subsequent correspondence, submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200021051(PDF, 7.4K) |
5/26/2000 |
| This letter responds to a letter dated January 22, 2000, and subsequent correspondence, written on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200021050(PDF, 10K) |
5/26/2000 |
| This is in response to your letter dated December 2, 1999, submitted on behalf of Company A, requesting a ruling under � 162(m) of the Internal Revenue Code. Specifically, the ruling requested is that the deduction limitation of � 162(m) of the Code does not apply to Company A and its United States subsidiaries. |
| 200021049(PDF, 22K) |
5/26/2000 |
| This is in reply to a letter dated September 24, 1999, in which rulings are requested as to the federal income tax consequences of a proposed transaction. |
| 200021048(PDF, 16K) |
5/26/2000 |
| This is in reply to a letter dated September 24, 1999, in which rulings are requested as to the federal income tax consequences of a proposed transaction. |
| 200021047(PDF, 15K) |
5/26/2000 |
| This letter responds to your letter dated September 9, 1999, on behalf of the above taxpayers, requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200021046(PDF, 19K) |
5/26/2000 |
| This is in reply to your letter dated October 4, 1999, requesting rulings under Treasury Regulation §1.367(a)-3(c)(9), that, based on your representations, the exchange of shares by U.S. persons will qualify for an exception to the general rule of � 367(a)(1) of the Internal Revenue Code of 1986, as amended . |
| 200021045(PDF, 12K) |
5/26/2000 |
| This is in response to your letter, dated October 20, 1999, requesting a private letter ruling providing that the failure to file notices of certain transactions under former Temp. Reg. §7.367(b)-1(c), in effect for the years of the transactions, was due to reasonable cause within the meaning of §7.367(b)-1(c)(3). |
| 200021044(PDF, 18K) |
5/26/2000 |
| This responds to your letter dated June 30, 1999, in which you requested rulings on certain federal income tax consequences of a proposed transaction, specifically under � 355 of the Internal Revenue Code. |
| 200021043(PDF, 17K) |
5/26/2000 |
| This is in reply to a letter dated November 15, 1999, in which rulings are requested as to the federal income tax consequences of a proposed transaction. |
| 200021042(PDF, 8.0K) |
5/26/2000 |
| This responds to a letter dated December 28, 1999, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200021041(PDF, 18K) |
5/26/2000 |
| This letter responds to a request dated December 20, 1999, for supplemental rulings with respect to a ruling letter dated November 5, 1999, (Control Number PLR-111814- 99, LTR 200005016) (the "Prior Ruling") involving the federal income tax consequences of a proposed transaction (the "Proposed Transaction.") |
| 200021040(PDF, 18K) |
5/26/2000 |
| This is in reply to a letter dated September 24, 1999, in which rulings are requested as to the federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated December 9, 1999, January 12, and February 17, 2000. The facts submitted for consideration are substantially as set forth below. |
| 200021039(PDF, 7K) |
5/26/2000 |
| This responds to your letter dated November 11, 1999, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200021038(PDF, 7K) |
5/26/2000 |
| This responds to a letter dated January 5, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200021037(PDF, 11K) |
5/26/2000 |
| This responds to a letter dated January 5, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200021036(PDF, 26K) |
5/26/2000 |
| This technical assistance responds to your memorandum dated March 10, 1999. You
requested our views on the tax treatment of certain adoption assistance payments
made by State to adoptive parents of special needs children. Specifically, you have
asked (1) whether adoption assistance payments to adoptive parents are taxable
income, and (2) whether State must issue a Form 1099 to the adoptive parents. |
| 200021035(PDF, 7K) |
5/26/2000 |
| This responds to a letter dated January 10, 2000, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200021034(PDF, 11K) |
5/26/2000 |
| This responds to your October 13, 1999, request for a ruling concerning § 40 of the Internal Revenue Code. Specifically, you request the Service to rule that: |
| 200021033(PDF, 7K) |
5/26/2000 |
| This letter responds to a letter dated November 19, 1999, and subsequent correspondence, written on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200021032(PDF, 11K) |
5/26/2000 |
| We respond to your October 18, 1999, request that we rule on the federal income tax consequences of a consummated transaction. |
| 200021031(PDF, 6K) |
5/26/2000 |
| This letter responds to your September 7, 1999 letter and subsequent correspondence submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200021030(PDF, 13K) |
5/26/2000 |
| This letter responds to your request dated October 21, 1999, for rulings on the federal income tax consequences of a proposed transaction. You submitted additional information in a letter dated January 31, 2000. |
| 200021029(PDF, 20K) |
5/26/2000 |
| This letter responds to your letter, dated October 15, 1999, requesting an extension of time under 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file elections. Purchaser is requesting the extension to file "section 338 elections," under 338(g) of the Internal Revenue Code and 1.338- 1(d) and 1.338-1(g) of the Income Tax Regulations with respect to Purchaser's acquisition of Target and deemed acquisition of Target Affiliate on Date A (sometimes hereinafter collectively referred to as the "Elections" or the "Election"). Additional information was received in letters dated December 15, 1999, January 14, January 24, and February 7, 2000. |
| 200021028(PDF, 7K) |
5/26/2000 |
| This letter responds to your letter dated October 5, 1999, as well as subsequent correspondence, in which you request a ruling under § 1362(f) of the Internal Revenue Code that the termination of Company's S corporation election was inadvertent. |
| 200021027(PDF, 7K) |
5/26/2000 |
| This letter responds to a letter dated October 10, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200021026(PDF, 8K) |
5/26/2000 |
| This letter responds to your letter, dated January 3, 2000, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation election will be effective as of the taxable year beginning D. |
| 200021025(PDF, 8K) |
5/26/2000 |
| This letter responds to your letter, dated October 19, 1999, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation election will be effective as of the taxable year beginning D. |
| 200021024(PDF, 9K) |
5/26/2000 |
| This is in response to your letter dated July 26, 1999, on behalf of A, 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. Additional information was submitted in a letter dated October 27, 1999. The information submitted for consideration is substantially as set forth below. |
| 200021023(PDF, 8K) |
5/26/2000 |
| This letter responds to your letter dated August 6, 1999, written on behalf of X, requesting a ruling that X be granted an extension of time in which to elect to treat its subsidiary, Sub, as a qualified subchapter S subsidiary under � 1361(b)(3)(B) of the Internal Revenue Code. |
| 200021022(PDF, 14K) |
5/26/2000 |
| This letter replies to a request for rulings, dated October 25, 1999, on the federal income tax consequences of a proposed transaction concerning § 355 of the Internal Revenue Code. We received additional information in letters dated December 16, 1999, January 5, January 12, and February 7, 2000. |
| 200021021(PDF, 9K) |
5/26/2000 |
| This responds to your letter dated November 18, 1999, on behalf of Decedent's estate requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make the alternate valuation election under § 2032(a) of the Internal Revenue Code. |
| 200021020(PDF, 16K) |
5/26/2000 |
| This is in response to your letter dated September 14, 1999, in which you requested rulings concerning the income and gift tax treatment of the establishment of a proposed charitable "lead" trust. |
| 200021019(PDF, 24K) |
5/26/2000 |
| This letter responds to your representative's September 24, 1999 request for rulings under § 368(a)(1)(C) of the Internal Revenue Code on behalf of the above-captioned taxpayers. Additional information with respect to the proposed transaction was submitted in letters dated December 10, 1999 and January 12, 2000. |
| 200021018(PDF, 24K) |
5/26/2000 |
| This letter responds to your representative's September 24, 1999 request for rulings under § 368(a)(1)(C) of the Internal Revenue Code on behalf of the above-captioned taxpayers. Additional information with respect to the proposed transaction was submitted in letters dated December 10, 1999 and January 12, 2000. |
| 200021017(PDF, 7K) |
5/26/2000 |
| This letter responds to a letter dated December 15, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200021016(PDF, 26K) |
5/26/2000 |
| This letter responds to your authorized representative's letter dated August 9, 1999, and subsequent correspondence, on behalf of Company requesting that Company not be required to recapture low-income housing tax credits under § 42(j)(1) of the Internal Revenue Code if Company reduces (or, in two instances, eliminates) the amount of bonds by the bonded amount attributable to credit previously claimed by certain Company subsidiaries. The Internal Revenue Service District Office that will have examination jurisdiction over all returns filed by Company is the X District. |
| 200021015(PDF, 7K) |
5/26/2000 |
| This letter responds to a letter dated September 22, 1999, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200021014(PDF, 15K) |
5/26/2000 |
| This letter is in response to your October 12, 1999 request for a ruling on behalf Taxpayer. Additional information was submitted on November 24, 1999 and January 28, 2000. |
| 200021013(PDF, 51K) |
5/26/2000 |
| Issues: (1) Can a portion of purchase costs of a ski resort, which are allocated to the construction costs of the resort's mountain roads, trails and slopes, be depreciated? (2) If such costs can be depreciated, what is the correct recovery period? (3) Can costs incurred subsequent to the purchase, attributable to maintenance of such mountain roads, trails and slopes, be depreciated? |
| 200021012(PDF, 14K) |
5/26/2000 |
| This responds to your letter dated August 11, 1999, requesting a ruling regarding the application of employment taxes to amounts deferred under the Plan. |
| 200021011(PDF, 42K) |
5/26/2000 |
| Issues: (1) Whether an allocation of income under Internal Revenue Code � 482 is appropriate between Purchasing Corp, the parent corporation of the Purchasing Corp consolidated group, and TargetCorp, a member of the Purchasing Corp consolidated group? (2) Whether TargetCorp's use of NOL carryovers are limited by the separate return limitation year (SRLY) rules. |
| 200021010(PDF, 31K) |
5/26/2000 |
| Issues: (1) Whether the "timely mailing equals timely filing" rule of Internal Revenue Code § 7502 can be applied to X and Y's joint income tax return for Year 1 when the return contains a claim for refund and is mailed on April 15, Year 3, but is not received by the Service until April 17, Year (3) (2) Whether X and Y's withheld income tax for Year 1, which was deemed paid on April 15, Year 2, was paid within the three year look back period of I.R.C. § 6511(b)(2)(A), where the due date of X and Y's income tax return for Year 1, was April 15, Year 2, which was a Saturday, and the Service received X and Y's joint income tax return for Year 1 on April 17, Year 3. |
| 200021009(PDF, 16K) |
5/26/2000 |
| This is in response to the letter of December 7, 1999, and earlier correspondence in which rulings are requested on the application of � 1001 of the Internal Revenue Code and the generation-skipping transfer tax to the proposed transaction described below. |
| 200021008(PDF, 17K) |
5/26/2000 |
| Issue: Whether, under the rules of � 83 of the Internal Revenue Code, Company A was entitled to deduct the compensation income that was includible in its employees' gross incomes as a result of cancellation of certain nonlapse restrictions on their Company A shares. This technical advice memorandum revokes and replaces technical advice memorandum numbered 199943040. |
| 200021007(PDF, 21K) |
5/26/2000 |
| In a letter, dated July 27, 1999, you requested several rulings concerning the income, gift, and generation-skipping transfer tax consequences of the partitioning of the Trust. This letter responds to your request. |
| 200021006(PDF, 27K) |
5/26/2000 |
| Issue: Whether in computing alternative minimum tax (AMT), Corp C has an adjusted current earnings (ACE) adjustment under Internal Revenue Code § 56(g)(4)(C)(i) for the use of percentage depletion for mining property placed in service in a tax year beginning prior to January 1, 1990, when its AMT basis in the mining property is adjusted basis for the purposes of � 612. |
| 200021005(PDF, 38K) |
5/26/2000 |
| Issues: (1) Whether this transaction is subject to Internal Revenue Code § 7872, and, if so, whether it is a demand or a term loan. (2) Whether § 482 may be applied to deem an interest payment subject to withholding tax, assuming that the note will be debt that is not subject to § 7872. |
| 200021003(PDF, 28K) |
5/26/2000 |
| Issues: (1) What expenses are intended to be included in the calculation of the "special deduction" allowed to Blue Cross and Blue Shield organizations under Internal Revenue Code § 833(a)(2)? (2) Whether Taxpayer has inappropriately included certain expenses in the calculation of the "special deduction" under � 833(a)(2). |
| 200021002(PDF, 29K) |
5/26/2000 |
| This is in response to your letter dated January 13, 1999, regarding a proposed transaction. Additional information was supplied in subsequent submissions. In a letter dated May 18, 1999, you withdrew requested rulings (5) and (7), modified ruling request (8) and requested two additional rulings. In a letter dated August 2, 1999, you withdrew ruling request (2) of the May 18, 1999 supplement ruling request. In a letter dated September 9, 1999, you withdrew requested ruling (10) of the January 13, 1999 submission. |
| 200021001(PDF, 33K) |
5/26/2000 |
| This is in connection with the attached memo, which we sent to you on August 19, 1999, on the issue of whether a retirement plan is a "retirement system" within the meaning of � 3121(b)(7)(F) of the Internal Revenue Code. We understand that our advice was requested in order for the advice in turn to be provided to a field office. Our memo therefore constitutes Chief Counsel Advice within the meaning of � 6110 and will be disclosed under the applicable 6110 procedures. |
| 200020063(PDF, 230K) |
2/25/2000 |
| This letter is in response to your request, dated November 15, 1999, in which you asked for a ruling on behalf of Taxpayer c as to whether certain proposed distributions from an individual retirement account (IRA) owned by Taxpayer C are part of a series of substantially equal periodic payments and are therefore not subject to the 10 percent additional tax imposed under � 72(t) of the Internal Revenue Code (Code). |
| 200020062(PDF, 453K) |
2/24/2000 |
| This letter is in response to a request for a ruling dated October 23, 1997, as supplemented by correspondence dated September IS, 1998, December 17, 1998, August 2, 1999, October 4, 1999, and December 28, I999 which was submitted on your behalf by your authorized representative, concerning an arrangement described under � 403(b)(7) of the Internal Revenue Code. |
| 200020061(PDF, 185K) |
2/24/2000 |
| This is in response to your request for a ruling, dated May 17, 1999, submitted by your authorized representative, as to whether Employer A is an agency or instrumentality of State M and that, as a result, Plan X and Plan Y constitute governmental plans within the meaning of � 414(d) of the Internal Revenue Code. Letters dated August 2, 1999 and October 5, 1999, and a telephone discussion on February 11, 2000, supplemented the request. |
| 200020060(PDF, 283K) |
2/24/2000 |
| A request for certain rulings concerning a proposed split-dollar life insurance arrangement involving Foundation and its President and Chief Executive Officer, Dr. X. The proposed arrangement is intended as part of a comprehensive compensation package for Dr. X. You have requested rulings that the proposed arrangement will not result in private inurement or adversely affect Foundation's exempt status under � 501 (c)(3) of the Internal Revenue Code and will not involve an act of self-dealing or a taxable expenditure under � 4941 and 4945 respectively. |
| 200020059(PDF, 319K) |
2/23/2000 |
| This is in response to your letter dated September 22, 1999, wherein you requested a ruling that a set-aside of funds by B be recognized as satisfying 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. |
| 200020058(PDF, 382K) |
2/22/2000 |
| Rulings with respect to a proposed transfer of assets from B to C, D, E, and F. B, C, D, E and F are exempt under � 501(c) 13) of the Internal Revenue Code and are classified as private foundations under � 509(a). |
| 200020057(PDF, 155K) |
2/18/2000 |
| For rulings concerning the federal income tax consequences of N's transfer of obligations and the assets that secure them to a for-profit entity pursuant to � 150(d)(3) of the Internal Revenue Code. |
| 200020056(PDF, 183K) |
2/10/2000 |
| Issues: (1) Whether M continues to qualify as a membership organization exempt under � 501(c)(6) of the Internal Revenue Code, and (2) Whether M is engaging in a regular business of a kind ordinarily carried on for profit within the meaning of � 513. |
| 200020055(PDF, 36K) |
5/19/2000 |
| Issue: What are the rules for determining the proper tax treatment of reimbursements that X provides to its personnel for travel expenses. |
| 200020054(PDF, 7K) |
5/19/2000 |
| August 25, 1999, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file Form 8279, Election To Be Treated as a FSC or as a Small FSC, pursuant to Temp. Treas. Reg. § 1.921-1T(b)(1), Q&A 1, effective for the tax year beginning on Date A. |
| 200020053(PDF, 10K) |
5/19/2000 |
| May 17, 1999, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the certification described in § 1.1503- 2A(d)(3) for TYE #3, #4, and #6 for Sub #1; TYE #1, #2, and #4 through #6 for Sub #2; and TYE #1 through #6 for Sub #3, and to replace such certifications with the agreement described in § 1.1503-2(g)(2) as provided in § 1.1503-2(h)(2) (ii); and to file the agreement described in § 1.1503-2(g)(2)(i) for TYE #8 through #10 for Subs #1 and #2; and for TYE #7, #10 and #11 for Sub #3. |
| 200020052(PDF, 20K) |
5/19/2000 |
| February 4, 2000 request that our ruling letter concerning the above taxpayers, which was addressed to you and dated September 30, 1999 ("Prior Letter Ruling") be amended. |
| 200020051(PDF, 13K) |
5/19/2000 |
| October 13, 1999, submitted on behalf of the Fund requesting an extension of time to elect, under � 855(a) of the Code, to treat dividends distributed after the close of the taxable year as having been paid during that year. |
| 200020050(PDF, 26K) |
5/19/2000 |
| November 9, 1999, as supplemented by your letter dated December 22, 1999, in which you requested a ruling and closing agreement that premiums received by 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 pursuant to the Income Tax Convention between the United States and the Federal Republic of Germany (the "Convention"). |
| 200020049(PDF, 10K) |
5/19/2000 |
| June 24, 1999, as amended by letters dated August 23, 1999, September 7, 1999, November 4, 1999, and January 18, 2000, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200020048(PDF, 63K) |
5/19/2000 |
| February 11, 1999, and supplemental correspondence, regarding certain federal income tax consequences of a proposed transaction. |
| 200020047(PDF, 10K) |
5/19/2000 |
| December 9, 1999, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's surrender of her U.S. Alien Registration Card (Green Card) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200020046(PDF, 20K) |
5/19/2000 |
| October 20, 1999, asking the Internal Revenue Service to rule on the transaction described below. |
| 200020045(PDF, 20K) |
5/19/2000 |
| October 20, 1999, asking the Internal Revenue Service to rule on the transaction described below. |
| 200020044(PDF, 21K) |
5/19/2000 |
| September 14, 1999, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file elections. |
| 200020043(PDF, 20K) |
5/19/2000 |
| November 23, 1999, asking the Internal Revenue Service to rule on the transaction described below. |
| 200020042(PDF, 7K) |
5/19/2000 |
| December 29, 1999, and subsequent correspondence, submitted on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200020041(PDF, 19K) |
5/19/2000 |
| September 10, 1999, requesting, on behalf of the taxpayers identified above, an extension of time under § 301.9100-1 through § 301.9100-3 of the Procedure and Administration Regulations to file elections. |
| 200020040(PDF, 8K) |
5/19/2000 |
| December 31, 1999 request for a private letter ruling, submitted on behalf of X, requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200020039(PDF, 20K) |
5/19/2000 |
| July 31, 1999, on behalf of the above taxpayers, requesting an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200020038(PDF, 16K) |
5/19/2000 |
| September 17 and November 10, 1999, submitted on behalf of Company, requesting a ruling under § 1362(f) of the Internal Revenue Code that the termination of Company's S corporation election was inadvertent. |
| 200020037(PDF, 8K) |
5/19/2000 |
| Request for a ruling dated October 12, 1999, submitted on behalf of the X Feeder Funds and the Y Feeder Funds (collectively, the "Feeder Funds"). |
| 200020036(PDF, 20K) |
5/19/2000 |
| October 12, 1999, submitted on behalf of the X Feeder Funds and the Y Feeder Funds (collectively, the "Feeder Funds"). |
| 200020035(PDF, 39K) |
5/19/2000 |
| Issue: Whether Internal Revenue Code § 351 does not apply to the exchange described below because it was not undertaken for a valid business purpose. |
| 200020034(PDF, 18K) |
5/19/2000 |
| September 28, 1999, submitted on behalf of Estate, of which you are Executor. Rulings are sought concerning the application of § 2055(e)(3) of the Internal Revenue Code to the proposed reformation of Trust, of which you are Trustee. |
| 200020033(PDF, 13K) |
5/19/2000 |
| September 9, 1999, written on behalf of X, requesting rulings under § 1362(b)(5) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations. |
| 200020032(PDF, 18K) |
5/19/2000 |
| September 14, 1999, in which rulings were requested on behalf of Distributing regarding certain federal income tax consequences of a proposed transaction. |
| 200020031(PDF, 20K) |
5/19/2000 |
| January 28, 2000, requesting rulings as to the federal income tax consequences of a proposed transaction. |
| 200020030(PDF, 19K) |
5/19/2000 |
| July 6, 1999 request for rulings on certain federal income tax consequences of a proposed transaction on behalf of the above-captioned taxpayer. |
| 200020029(PDF, 25K) |
5/19/2000 |
| Issues: Entity has requested the following rulings: (1) Is Entity exempt from the Federal Unemployment Tax Act (FUTA) under § 3306(c)(7) of the Internal Revenue Code? (2) Are contributions and gifts to or for the use of Entity charitable contributions within the meaning of § 170(c)(1) of the Code? |
| 200020028(PDF, 10K) |
5/19/2000 |
| December 7, 1999, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that your loss of citizenship (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200020027(PDF, 9K) |
5/19/2000 |
| November 5, 1999, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200020026(PDF, 7K) |
5/19/2000 |
| December 6, 1999,submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200020025(PDF, 10K) |
5/19/2000 |
| December 7, 1999, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that your loss of citizenship (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200020024(PDF, 37K) |
5/19/2000 |
| October 21, 1999, and prior correspondence, in which you requested rulings concerning the income, estate, and generation-skipping transfer tax consequences of the proposed merger of several trusts. |
| 200020023(PDF, 37K) |
5/19/2000 |
| October 21, 1999, and prior correspondence, in which you requested rulings concerning the income, estate, and generation-skipping transfer tax consequences of the proposed merger of several trusts. |
| 200020022(PDF, 13K) |
5/19/2000 |
| December 22, 1999, written on X's behalf, requesting inadvertent termination relief under � 1362(f) of the Internal Revenue Code. |
| 200020021(PDF, 10K) |
5/19/2000 |
| June 30, 1998, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that your proposed loss of U.S. citizenship (expatriation) will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200020020(PDF, 37K) |
5/19/2000 |
| October 21, 1999, and prior correspondence, in which you requested rulings concerning the income, estate, and generation-skipping transfer tax consequences of the proposed merger of several trusts. |
| 200020019(PDF, 37K) |
5/19/2000 |
| October 21, 1999, and prior correspondence, in which you requested rulings concerning the income, estate, and generation-skipping transfer tax consequences of the proposed merger of several trusts. |
| 200020018(PDF, 24K) |
5/19/2000 |
| August 17, 1999, requesting rulings under Treasury Regulation §1.367(a)-3(c)(9), that, based on your representations, the exchange of shares by U.S. persons will qualify for an exception to the general rule of � 367(a)(1) of the Internal Revenue Code of 1986, as amended . |
| 200020017(PDF, 10K) |
5/19/2000 |
| December 7, 1999, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that your loss of citizenship (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. Additional information was submitted in a letter dated January 11, 2000. |
| 200020016(PDF, 10K) |
5/19/2000 |
| May 7, 1998, and supplemental letters, submitted by your authorized representatives 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. |
| 200020015(PDF, 37K) |
5/19/2000 |
| October 21, 1999, and prior correspondence, in which you requested rulings concerning the income, estate, and generation-skipping transfer tax consequences of the proposed merger of several trusts. |
| 200020014(PDF, 37K) |
5/19/2000 |
| October 21, 1999, and prior correspondence, in which you requested rulings concerning the income, estate, and generation-skipping transfer tax consequences of the proposed merger of several trusts. |
| 200020013(PDF, 10K) |
5/19/2000 |
| January 27, 2000, submitted on behalf of X, requesting a ruling that the rental income received by X from renting certain properties is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200020012(PDF, 37K) |
5/19/2000 |
| October 21, 1999, and prior correspondence, in which you requested rulings concerning the income, estate, and generation-skipping transfer tax consequences of the proposed merger of several trusts. |
| 200020011(PDF, 13K) |
5/19/2000 |
| August 28, 1998, submitted on behalf of Decedent's estate, requesting a ruling concerning the deductibility of interest expense under § 2053 of the Internal Revenue Code. |
| 200020010(PDF, 37K) |
5/19/2000 |
| October 21, 1999, and prior correspondence, in which you requested rulings concerning the income, estate, and generation-skipping transfer tax consequences of the proposed merger of several trusts. |
| 200020009(PDF, 31K) |
5/19/2000 |
| Issue: Whether the Exempt Organization is liable for the excise tax under Internal Revenue Code § 4972(a), if it is liable for tax under the provisions of I.R.C. § 6033(e)(2). |
| 200020008(PDF, 12K) |
5/19/2000 |
| October 5, 1999, in which a ruling is requested that Incentive Stock Options granted under the Plan are options described in � 422 of the Internal Revenue Code. |
| 200020007(PDF, 10K) |
5/19/2000 |
| December 1, 1999, requesting a ruling that Company will produce a qualified fuel within the meaning of � 29(c)(1)(C) of the Internal Revenue Code. |
| 200020006(PDF, 15K) |
5/19/2000 |
| October 13, 1999, you requested rulings regarding your purchase of oil and gas properties. |
| 200020005(PDF, 26K) |
5/19/2000 |
| Issue: Whether developmentally disabled individuals in the sheltered employment program of X are employees for federal employment tax purposes. |
| 200020004(PDF, 25K) |
5/19/2000 |
| Issue: Whether developmentally disabled individuals in the sheltered employment program of X are employees for federal employment tax purposes. |
| 200020003(PDF, 8K) |
5/19/2000 |
| Request for a private letter ruling, submitted on behalf of X, requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200020002(PDF, 25K) |
5/19/2000 |
| September 10, 1999 request for rulings on certain federal income tax consequences of the proposed transactions described below. |
| 200020001(PDF, 10K) |
5/19/2000 |
| December 1, 1999, requesting a ruling that Company will produce a qualified fuel within the meaning of � 29(c)(1)(C) of the Internal Revenue Code. |
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