2002 Chief Counsel's
Written Determinations
200205000 to 200209999
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.
| 200209062(PDF, 32K) |
4/12/2002 |
| This is in response to the, letter submitted on your behalf by your authorized representative, in which you request a letter ruling under � 401(a)(9) of the Internal Revenue Code. |
| 200209061(PDF, 28K) |
4/12/2002 |
| This is in response to your letter dated September 21, 2001, in which you requested a ruling that grants distributed through D will be considered qualifying distributions made directly for the active conduct of activities constituting your exempt purpose under � 4942. |
| 200209060(PDF, 38K) |
4/12/2002 |
| This is in response to a letter dated June 8, 2001, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations (the "regulations"). The following facts and representations were submitted in connection with your request. |
| 200209059(PDF, 52K) |
4/12/2002 |
| This is in response to your request for a private letter ruling dated September 22, 2000, as supplemented by correspondence dated November 8, 2001. In support of your request, you have submitted the following facts and representations. |
| 200209058(PDF, 49K) |
4/12/2002 |
| This is in response to your request for a private letter ruling dated September 22, 2000, as supplemented by correspondence dated November 8, 2001. In support of your request, you have submitted the following facts and representations. |
| 200209057(PDF, 51K) |
4/12/2002 |
| This is in response to your request for a private letter ruling dated September 22, 2000, as supplemented by correspondence dated November 8, 2001. In support of your request, you have submitted the following facts and representations. |
| 200209056(PDF, 42K) |
4/12/2002 |
| This is in response to a letter dated August 22, 2001, submitted by your authorized representative, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations (the "regulations"). The following facts and representations were submitted in connection with your request. |
| 200209055(PDF, 28K) |
4/12/2002 |
| This letter responds to X's request, dated April 6, 2000, for rulings under � 4945 and 4942 of the Internal Revenue Code concerning grants to Y, a foreign organization. |
| 200209054(PDF, 15K) |
2/7/2002 |
| This is in reply to a letter dated March 27, 2001, and subsequent correspondence, submitted by your authorized representative, requesting an extension of time under � 301.9100 of the Procedure and Administration Regulations to make an election under � 475(f) of the Internal Revenue Code to use the mark-to-market method of accounting for the Year 2 tax year. |
| 200209053(PDF, 16K) |
2/7/2002 |
| This is in reply to a letter dated October 27, 2000, and subsequent correspondence, submitted on your behalf by authorized representatives, requesting an extension of time under � 301.9100 of the Procedure and Administration Regulations to make an election under � 475(f) of the Internal Revenue Code to use the mark-to-market method of accounting for the Year 2 tax year. |
| 200209052(PDF, 14K) |
2/7/2002 |
| This ruling is in reply to a letter dated April 27, 2001, and subsequent correspondence, requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to make an election under � 475(f) of the Internal Revenue Code to use the mark-to-market method of accounting for the year ending Date 1. |
| 200209051(PDF, 14K) |
2/7/2002 |
| We respond to your June 7, 2001 request for rulings on certain federal income tax consequences of a proposed sale of stock. |
| 200209050(PDF, 6K) |
2/7/2002 |
| This responds to a letter dated August 29, 2001, and subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200209049(PDF, 12K) |
2/7/2002 |
| We respond to your letter dated April 3, 2001, requesting rulings on the federal income tax consequences of a proposed transaction. The information submitted in your request and in subsequent correspondence is summarized below. |
| 200209048(PDF, 7K) |
2/7/2002 |
| This letter responds to a letter dated October 5, 2001, submitted on behalf of X, requesting a ruling that X be granted an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election under � 301.7701-3(c) to be treated as a corporation for federal tax purposes. |
| 200209047(PDF, 18K) |
2/7/2002 |
| We respond to your letter dated June 28, 2001, for rulings concerning the Federal income tax consequences of a proposed transaction. |
| 200209046(PDF, 8K) |
2/7/2002 |
| This letter responds to a request submitted on behalf of LLC, dated September 12, 2001, seeking a written determination allowing an extension of time for LLC to make an election under � 754 of the Internal Revenue Code. |
| 200209045(PDF, 17K) |
2/7/2002 |
| This is in response to your letter dated June 12, 2001, requesting a ruling under § 2601 of the Internal Revenue Code. |
| 200209044(PDF, 34K) |
2/7/2002 |
| This letter responds to a letter dated September 29, 2000 and subsequent correspondence, submitted on behalf of P by its authorized representative, requesting rulings under � 29 and 702 of the Internal Revenue Code. |
| 200209043(PDF, 17K) |
2/7/2002 |
| This is in response to your letter dated June 12, 2001, requesting a ruling under § 2601 of the Internal Revenue Code. |
| 200209042(PDF, 17K) |
2/7/2002 |
| This is in response to your letter dated June 12, 2001, requesting a ruling under § 2601 of the Internal Revenue Code. |
| 200209041(PDF, 7K) |
2/7/2002 |
| This responds to the letter dated July 26, 2001, submitted on behalf of X, requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations for X to elect to be treated as a corporation for federal tax purposes. |
| 200209040(PDF, 7K) |
2/7/2002 |
| This letter responds to your letter dated July 31, 2001, submitted on behalf of Entity, requesting an extension of time for Entity to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be treated as an association taxable as a corporation. |
| 200209039(PDF, 17K) |
2/7/2002 |
| This is in response to your letter dated June 12, 2001, requesting a ruling under § 2601 of the Internal Revenue Code. |
| 200209038(PDF, 16K) |
2/7/2002 |
| This is in response to the August 21, 2001 letter and other correspondence requesting a ruling on the generation-skipping transfer tax consequences of the judicial amendment of Amended Trust. |
| 200209037(PDF, 16K) |
2/7/2002 |
| This is in response to the August 21, 2001 letter and other correspondence requesting a ruling on the generation-skipping transfer tax consequences of the judicial amendment of Amended Trust. |
| 200209036(PDF, 17K) |
2/7/2002 |
| This is in response to your letter dated June 12, 2001, requesting a ruling under § 2601 of the Internal Revenue Code. |
| 200209035(PDF, 17K) |
2/7/2002 |
| This is in response to your letter dated June 12, 2001, requesting a ruling under § 2601 of the Internal Revenue Code. |
| 200209034(PDF, 16K) |
2/7/2002 |
| This is in response to the August 21, 2001 letter and other correspondence requesting a ruling on the generation-skipping transfer tax consequences of the judicial amendment of Amended Trust. |
| 200209033(PDF, 16K) |
2/7/2002 |
| This is in response to the August 21, 2001 letter and other correspondence requesting a ruling on the generation-skipping transfer tax consequences of the judicial amendment of Amended Trust. |
| 200209032(PDF, 17K) |
2/7/2002 |
| This is in response to your letter dated June 12, 2001, requesting a ruling under § 2601 of the Internal Revenue Code. |
| 200209031(PDF, 6K) |
2/7/2002 |
| This responds to a letter dated October 9, 2001, submitted by X�s authorized representative on behalf of X, requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200209030(PDF, 10K) |
2/7/2002 |
| This is in response to your letter dated May 3, 2001, requesting a ruling on behalf of A under � 877(c) of the Internal Revenue Code of 1986 (the "Code") that A's loss of permanent 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. |
| 200209029(PDF, 62K) |
2/7/2002 |
| This letter responds to your February 23, 2001 request for a letter ruling supplementing our prior letter ruling dated April 26, 2000 (the "Prior Letter Ruling"). The legend abbreviations, factual summary, and representations appearing in the Prior Letter Ruling are hereby incorporated by reference except as otherwise stated. |
| 200209028(PDF, 31K) |
2/21/2002 |
| Issue: Whether a taxpayer may prepare a refund claim based on adjustments that are obtained from projecting the results of an analysis of a statistical sampling of meals & entertainment expenditures across the total population of Internal Revenue Code § 274 meals & entertainment expense. |
| 200209027(PDF, 8K) |
2/7/2002 |
| This is in response to a letter dated May 14, 2001, as supplemented by letters dated June 28, 2001, October 4, 2001, and November 12, 2001, submitted by A's authorized representative requesting a ruling, under � 877(c) of the Internal Revenue Code , 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. |
| 200209026(PDF, 17K) |
2/7/2002 |
| This letter responds to a letter dated June 25, 2001, submitted by you as the co-executor of Estate, requesting certain rulings under §§ 691 and 894 of the Internal Revenue Code. |
| 200209025(PDF, 15K) |
2/6/2002 |
| Issue: Whether the § 481 adjustment for a consolidated return member changing its method of accounting needs to take into account the corresponding adjustments that might be required of another member's method of accounting for intercompany transactions? |
| 200209024(PDF, 26K) |
2/8/2002 |
| This is in response to your request for rulings dated July 5, 2001, submitted on behalf of Coop by your representative. |
| 200209023(PDF, 6K) |
2/6/2002 |
| This letter responds to a letter dated September 15, 2001, submitted on behalf of X by X's authorized representative, requesting a ruling under §1362(b)(5) of the Internal Revenue Code. |
| 200209022(PDF, 16K) |
2/6/2002 |
| This is in response to the August 21, 2001 letter and other correspondence requesting a ruling on the generation-skipping transfer tax consequences of the judicial amendment of Amended Trust. |
| 200209021(PDF, 13K) |
2/6/2002 |
| This letter responds to a letter dated October 29, 2001, 2001, submitted on behalf of Parent, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as the common parent of the consolidated group of which Sub 1, the United States shareholder of Purchaser, the "foreign purchasing corporation," is a member) is requesting an extension to file a "§ 338 election" under § 338(g) with respect to the acquisition of the stock of Target Sub (sometimes hereinafter referred to as the "Election"), on Date A. (All citations in this letter to regulations under § 338 are to regulations in effect on Date A.) |
| 200209020(PDF, 16K) |
2/6/2002 |
| This responds to your letter dated November 30, 2000, and other supplemental material, in which you request a ruling related to a transfer of a life insurance policy to a charitable organization. |
| 200209019(PDF, 14K) |
2/8/2002 |
| On November 20, 2000, the Internal Revenue Service issued PLR 200107030 (PLR-110764-00) to X granting a ruling request under § 1362(f) of the Internal Revenue Code. In a letter dated D7, you informed us of an error in the statement of facts presented in the original ruling request. Accordingly, PLR 200107030 is revoked and replaced with this letter which is in accord with the facts of your D7 letter. The conclusions of PLR 200107030 remain the same. |
| 200209018(PDF, 17K) |
2/6/2002 |
| This letter responds to your July 12, 2001 request for rulings on certain federal income tax consequences of a proposed transaction. |
| 200209017(PDF, 35K) |
2/21/2002 |
| Issues: (1) Whether a transaction by which a self-insured company retroactively insures "known" losses arising under workers' compensation acts constitutes insurance for federal income tax purposes? (2) Assuming the transaction does not constitute insurance for federal income tax purposes, when does economic performance occur with regard to the "premium" payments made by the company? |
| 200209016(PDF, 12K) |
2/6/2002 |
| This is in reference to a Form 1128, Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayers, husband and wife (hereinafter taxpayer), requesting permission to change its annual accounting period, for federal income tax purposes, from a taxable year ending October 31, to a calendar year ending December 31, effective for the tax year beginning November 1, 2000, and ending December 31, 2000. The taxpayer has requested that the Form 1128 be considered timely filed under the authority contained in §301.9100-3 of the Procedure and Administration Regulations. |
| 200209015(PDF, 24K) |
2/6/2002 |
| This responds to a letter dated December 1, 2000, and subsequent correspondence, written on behalf of the Tribe, requesting a ruling under § 676 of the Internal Revenue Code. |
| 200209014(PDF, 27K) |
2/8/2002 |
| This letter responds to a letter dated July 7, 2000, and subsequent correspondence, submitted on behalf of P by its authorized representative, requesting rulings under � 29 of the Internal Revenue Code. |
| 200209013(PDF, 6K) |
2/8/2002 |
| This responds to the letter dated September 17, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200209012(PDF, 6K) |
2/6/2002 |
| This letter responds to your letter dated May 22, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200209011(PDF, 13K) |
2/7/2002 |
| This letter responds to a letter dated August 31, 2001, submitted on behalf of Taxpayer, requesting a private letter ruling regarding the application of � 42(j) of the Internal Revenue Code to a proposed transfer of bare legal title to certain real property owned by Taxpayer to Authority. |
| 200209010(PDF, 67K) |
2/6/2002 |
| This letter responds to Taxpayer/Parent 2's request, dated September 24, 1999, that we rule on certain tax consequences under the Internal Revenue Code of the transfer of the Plants and associated nuclear decommissioning funds. As set forth below, you have requested rulings regarding the tax consequences to Taxpayer/Parent 2, its subsidiaries (Companies 2, 3, 4), and its qualified nuclear decommissioning funds. |
| 200209009(PDF, 8K) |
2/8/2002 |
| This responds to your letter dated, September 17, 2001 in which you requested relief under � 301.9100-3 of the Procedure and Administration Regulations to file an election under � 301.7701-3(c) to be treated as a partnership for federal tax purposes. |
| 200209008(PDF, 44K) |
2/8/2002 |
| This is in response to your authorized representative's letter, dated November 10, 2000, and subsequent submissions, requesting rulings on the income tax, gift tax, and generation-skipping transfer tax ("GSTT") consequences of the modification of a trust. |
| 200209007(PDF, 44K) |
2/8/2002 |
| This is in response to your authorized representative's letter, dated November 10, 2000, and subsequent submissions, requesting rulings on the income tax, gift tax, and generation-skipping transfer tax ("GSTT") consequences of the modification of a trust. |
| 200209006(PDF, 23K) |
2/6/2002 |
| Issue: Whether a document submitted to an Appeals officer containing only zeros constitutes a return? |
| 200209005(PDF, 7K) |
2/6/2002 |
| This is in response to your request on behalf of the Issuer for a ruling that the Issuer's change * * * in the Program will not cause the Bonds to fail to be described in the Provision. |
| 200209004(PDF, 31K) |
2/6/2002 |
| Issue: Whether refund claims regarding overpaid employment taxes constitute valid claims for refund under � 6402 of the Internal Revenue Code. |
| 200209003(PDF, 84K) |
2/8/2002 |
| Issues: (1) Whether payments to Provider A may be taken into account when calculating the yield on the yield restricted defeasance escrows. (2) Whether the Authority paid Provider B more than fair market value for the investments it purchased for the yield restricted defeasance escrows. |
| 200209002(PDF, 10K) |
2/8/2002 |
| This letter responds to a letter dated June 27, 2001, requesting, on behalf of Taxpayer, an extension of time under § 301.9100-1 through § 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Taxpayer to file an election under § 1.1502-21(b)(3)(i) of the Income Tax Regulations to relinquish the entire carryback period for the consolidated net operating loss ("CNOL") of the consolidated group of which the Taxpayer was the common parent for the tax year ending Date 1. |
| 200209001(PDF, 85K) |
2/6/2002 |
| Issues: (1) Whether the lease stripping transactions lack economic substance. (2) Whether � 482 applies to the lease-stripping transactions at issue, and if so, the consequences of applying � 482. |
| 200208039(PDF, 31K) |
4/12/2002 |
| We have considered your ruling request dated June 1, 2000 for a ruling that the proposed early termination of X will not constitute self-dealing under � 4941 (d) of the Code. |
| 200208038(PDF, 38K) |
4/12/2002 |
| This is in response to the September 7, 2001 letter, submitted by your authorized representative, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations. |
| 200208037(PDF, 32K) |
4/12/2002 |
| This letter is in response to a request by your authorized representative for rulings on the excise tax applicable to a reversion of surplus assets to the Company on account of the termination of the DB Plan and the transfer of a portion of the surplus to the 401 (k) Plan. Letters dated October 30, 2001, and November 16, 2001, modified the request. |
| 200208036(PDF, 34K) |
4/12/2002 |
| This is in response to a letter dated May 14, 2001, as supplemented by correspondence dated September 21, 2001, and November 2, 2001, submitted by your authorized representative, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations (the "regulations"). The following facts and representations were submitted in connection with your request. |
| 200208035(PDF, 38K) |
4/12/2002 |
| This is in response to a letter dated June 28, 2001, as supplemented by correspondence dated October 29, 2001 and November 14, 2001, as submitted by your authorized representative, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations (the "regulations"). The following facts and representations were submitted in connection with your request. |
| 200208034(PDF, 39K) |
4/12/2002 |
| This is in response to a letter dated August 8, 2001, as supplemented by correspondence dated November 7, 2001, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations (the "regulations"). The following facts and representations were submitted in connection with your request. |
| 200208033(PDF, 48K) |
4/12/2002 |
| This is in response to a request for a private letter ruling dated September 27, 2000, as revised and supplemented by letters of March 1, 2001, March 27, 2001, March 30, 2001, July 20, 2001, July 31, 2001, August 30, 2001, and October 2, 2001, submitted on your behalf by your authorized representative. In support of your request, your authorized representative has submitted the following facts and representations. |
| 200208032(PDF, 237K) |
4/12/2002 |
| This is in response to a letter dated July 3, 2001, as supplemented by correspondence dated November 5, 2001, and November 7, 2001, submitted by your authorized representative, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations (the "regulations"). The following facts and representations were submitted in connection with your request. |
| 200208031(PDF, 54K) |
4/12/2002 |
| This is in response to the letter submitted on your behalf by your authorized representative in which you, through your representative, request letter rulings under � 402(c) and 401(a)(9) of the Internal Revenue Code. |
| 200208030(PDF, 49K) |
4/12/2002 |
| This is in response to a request for a private letter ruling dated September 27, 2000, as revised and supplemented by letters of March 1, 2001, March 27, 2001, March 30, 2001, July 20, 2001, July 31, 2001, August 30, 2001, and October 2, 2001, submitted on your behalf by your authorized representative. In support of your request, your authorized representative has submitted the following facts and representations. |
| 200208029(PDF, 55K) |
4/12/2002 |
| This is in response to a request for a private letter ruling dated September 27, 2000, as revised and supplemented by letters of March 1, 2001, March 27, 2001, March 30, 2001, July 20, 2001, July 31, 2001, August 30, 2001, and October 2, 2001, submitted on your behalf by your authorized representative. In support of your request, your authorized representative has submitted the following facts and representations. |
| 200208028(PDF, 53K) |
4/12/2002 |
| This is in response to a request for a private letter ruling dated September 27, 2000, as revised and supplemented by letters of March 1, 2001, March 27, 2001, March 30, 2001, July 20, 2001, July 31, 2001, August 30, 2001, and October 2, 2001, submitted on your behalf by your authorized representative. In support of your request, your authorized representative has submitted the following facts and representations. |
| 200208027(PDF, 48K) |
4/12/2002 |
| Issues: (1) Whether; for purposes of � 512(b)(13) of the Internal Revenue Code, M controls N so imputed interest on loans, excess dues and assessments, and funds advanced by N to 0 constitute unrelated business taxable income under � 512(a)(l) with respect to M. (2) Whether, for purposes of � 512(b)(13) of the Code, the activities of N should be attributed to M, so imputed interest on loans, excess dues and assessments, and funds advanced by N to 0 constitute unrelated business taxable income under � 512(a)(l) with respect to M. (3) Whether M continues to meet the requirements for classification as a supporting organization under � 509(a)(3) of the Code, or whether M should be reclassified as a private foundation under � 509(a). |
| 200208026(PDF, 11K) |
2/1/2002 |
| This memorandum constitutes Chief Counsel Advice. In accordance with � 6610(k)(3), this Chief Counsel Advice should not be cited as precedent. |
| 200208025(PDF, 11K) |
2/1/2002 |
| Issue: Where a corporate taxpayer has substantially defaulted on making payments under a confirmed Chapter 11 plan, and assuming that the Service is entitled to collect the amount still due under the plan, should the assessments of the tax liabilities discharged by the confirmation and not provided for by the plan be abated, pursuant to Internal Revenue Code § 6404(c), to assist the Service in collecting the liabilities provided for by the plan? |
| 200208024(PDF, 23K) |
2/1/2002 |
| Issue: What date is the "applicable date" for computing Internal Revenue Code § 6621(c) interest (hot interest) on a large corporate underpayment of tax that was proposed in a second 30-day letter, where the taxpayer did not fully pay the amount reflected in the first 30-day letter within thirty days? |
| 200208023(PDF, 7K) |
2/1/2002 |
| This replies to a letter dated May 7, 2001, submitted on your behalf by your authorized representative, in which an extension of time is requested under Treasury Regulation § 301.9100-3 to allow Taxpayer to file the following with respect to Entity A: (i) the agreement described in § 1.1503-2(g)(2)(i) for each of the tax years ended on Dates A and B; and (ii) the annual certification described in § 1.1503-2(g)(2)(vi), which was required to be attached to the tax return filed for the fiscal year ended on Date B with respect to the losses arising in the tax year ended on Date A. (Hereinafter the agreement and the annual certification will sometimes be referred to collectively as "the statements".) |
| 200208022(PDF, 34K) |
2/1/2002 |
| This is in response to your letter dated August 1, 2001, in which rulings are requested as to the federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated August 23, September 14, October 24, and November 9, 2001. |
| 200208021(PDF, 7K) |
2/1/2002 |
| This letter responds to a letter, dated June 1, 2001, and subsequent correspondence by your authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200208020(PDF, 6K) |
2/1/2002 |
| This letter responds to a letter received July 23, 2001, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200208019(PDF, 37K) |
2/12/2002 |
| This responds to your letter dated May 8, 2001, requesting a ruling on the proper federal income tax treatment of a proposed grant of a conservation easement by Taxpayer to ConOrg 1 with respect to land owned by Taxpayer in County X, State X, as supplemented by letters and submissions dated June 14, July 24, July 31 and October 11, 2001. |
| 200208018(PDF, 16K) |
2/1/2002 |
| This letter responds to your request, dated May 1, 2001, requesting rulings under � 301.9100-1 of the Procedure and Administration Regulations as well as rulings under § 2632 and § 2652 of the Internal Revenue Code. |
| 200208017(PDF, 26K) |
2/1/2002 |
| This letter responds to your authorized representative�s letter dated June 20, 2001, requesting, on behalf of Taxpayer, an extension of time under �� 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Taxpayer is requesting an extension to file an election (the �Election�) under � 1.337(d)-5T(b) and (c) to be subject to the rules of � 1374 of the Internal Revenue Code with respect to assets it received from Parent, a C corporation. The material information is summarized below. |
| 200208016(PDF, 13K) |
2/1/2002 |
| This is in reply to the private letter ruling request in which Taxpayer requests permission to change an election it made under § 108(b)(5) of the Internal Revenue Code. |
| 200208015(PDF, 9K) |
2/1/2002 |
| This is in response to a letter from your authorized representative dated July 18, 2001, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's 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 November 6, 2001. |
| 200208014(PDF, 12K) |
2/1/2002 |
| This is in response to a request submitted by the Administration for an extension of time under § 301.9100-1 of the Procedure and Administrative Regulations to file a Form 8328 to make a carryforward election under § 146(f) of the Internal Revenue Code and for a ruling that the Authority may assume the Administration's carryforward allocation of the state private activity bond volume cap as the Administration's successor entity. |
| 200208013(PDF, 10K) |
2/1/2002 |
| This letter responds to your letter dated May 22, 2001, and subsequent correspondence, written on behalf of Y, requesting extensions of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to make qualified subchapter S subsidiary elections for Sub under § 1361(b)(3) of the Internal Revenue Code. |
| 200208012(PDF, 7K) |
2/1/2002 |
| This responds to your letter dated October 23, 2001, submitted on behalf of X, requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations to elect to treat Y as a qualified subchapter S subsidiary for federal tax purposes. |
| 200208011(PDF, 6K) |
2/1/2002 |
| This letter responds to your request dated D1, submitted on behalf of Taxpayer, requesting under §301.9100-3 of the Procedure and Administration Regulations an extension of time to file a request for a revised schedule of ruling amounts for Plant under §1.468A-3(i)(1)(i) of the Income Tax Regulations for the period beginning D2 and ending D3. |
| 200208010(PDF, 6K) |
2/1/2002 |
| This letter responds to your request dated D1, submitted on behalf of Taxpayer, requesting under §301.9100-3 of the Procedure and Administration Regulations an extension of time to file a request for a revised schedule of ruling amounts for Plant under §1.468A-3(i)(1)(i) of the Income Tax Regulations for the period beginning D2 and ending D3. |
| 200208009(PDF, 6K) |
2/1/2002 |
| This responds to your representative's letter dated July 26, 2001, submitted on behalf of X, requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200208008(PDF, 6K) |
2/1/2002 |
| This letter responds to your letter dated July 12, 2001, submitted on behalf of X as X's authorized representative, requesting a ruling under §1362(b)(5) of the Internal Revenue Code. |
| 200208007(PDF, 9K) |
2/1/2002 |
| This responds to a letter dated January 29, 2001, and subsequent correspondence submitted on behalf of X, requesting a ruling that X's rental income from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200208006(PDF, 7K) |
2/1/2002 |
| This responds to your letter dated, September 17, 2001, submitted on behalf of X, requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations to elect to treat X as a qualified subchapter S subsidiary for federal tax purposes. |
| 200208005(PDF, 6K) |
2/1/2002 |
| This letter responds to a letter, dated June 21, 2001, submitted by your authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200208004(PDF, 68K) |
2/1/2002 |
| This letter responds to Taxpayer/Company 1's request, dated September 24, 1999, that we rule on certain tax consequences under the Internal Revenue Code of the transfer of the Plants and associated nuclear decommissioning funds. As set forth below, you have requested rulings regarding the tax consequences to Taxpayer/Company 1 and its qualified nuclear decommissioning funds. |
| 200208003(PDF, 23K) |
2/1/2002 |
| This is in response to your letter dated July 10, 2000, requesting rulings on behalf of Taxpayer regarding the application of the tax benefit rule and � 4976 of the Internal Revenue Code to the transaction described below. |
| 200208002(PDF, 43K) |
2/1/2002 |
| Issue: Whether �supervisory goodwill� qualifies as �money or other property� for purposes of � 597 of the Code? |
| 200208001(PDF, 8K) |
2/1/2002 |
| This is in response to your letter dated May 16, 2001, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200207031(PDF, 31K) |
4/12/2002 |
| This is in response to your representative�s letter, dated November 21, 2001, submitted on behalf of Decedent�s estate, requesting an extension of time under �� 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an election under � 2057(b)(1)(B) of the Internal Revenue Code. |
| 200207030(PDF, 31K) |
4/12/2002 |
| This letter is in response to your request for ruling for authority to create a contingent set-aside pursuant to � 53.4942(a)-3(b)(9) of the Foundation Excise and Similar regulations. |
| 200207029(PDF, 37K) |
4/12/2002 |
| We have considered your ruling request, along with supplemental correspondence, concerning the application of � 4941 of the Internal Revenue Code, specifically the estate or trust administration exception from self-dealing under � 53.4941 (d)-1 (b)(3) of the Foundation and Similar Excise Tax Regulations. |
| 200207028(PDF, 37K) |
4/12/2002 |
| We have considered your ruling request, along with supplemental correspondence, concerning the application of � 4941 of the Internal Revenue Code, specifically the estate or trust administration exception from self-dealing under � 53.4941 (d)-1 (b)(3) of the Foundation and Similar Excise Tax Regulations. |
| 200207027(PDF, 74K) |
4/12/2002 |
| This is in response to a letter dated September 18, 2000, as supplemented by additional correspondence dated August 2, 2001, in which your authorized representative requested a ruling on your behalf under � 414(e) of the Internal Revenue Code . |
| 200207026(PDF, 22K) |
1/28/2002 |
| This responds to your letter dated October 19, 2000, and subsequent correspondence, submitted on behalf of Trust and Donor, requesting rulings under §§ 170, 2522, and 664 of the Internal Revenue Code on the income and gift tax consequences of the contribution of a portion of an interest in a trust (Trust) to a charitable remainder beneficiary of Trust. |
| 200207025(PDF, 18K) |
1/28/2002 |
| This letter responds to your July 30, 2001 request submitted on behalf of Distributing, Shareholder 1 and Shareholder 2, for rulings on certain federal income tax consequences of a proposed transaction. |
| 200207024(PDF, 10K) |
1/28/2002 |
| This is in reply to a letter dated July 25, 2001, requesting an extension of time, under � 1.9100-3 of the Income Tax Regulations, for Funds 1 through 5 to make the election under � 855(a) of the Internal Revenue Code and � 1.855-1(b)(1). |
| 200207023(PDF, 6K) |
1/28/2002 |
| This letter responds to your request dated July 12, 2001, and subsequent submissions submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200207022(PDF, 6K) |
1/28/2002 |
| This responds to a letter dated August 27, 2001, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200207021(PDF, 6K) |
2/5/2002 |
| This responds to your letter dated October 2, 2001, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200207020(PDF, 11K) |
1/28/2002 |
| This is in reply to a letter dated July 12, 2001, on behalf of Fund. Fund requests consent to revoke, for Year and subsequent calendar years, an election previously made under � 4982(e)(4)(A) of the Internal Revenue Code. |
| 200207019(PDF, 9K) |
1/28/2002 |
| This is in reply to a letter dated July 3, 2001, and subsequent correspondence submitted on behalf of X, requesting a ruling that X be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be disregarded as an entity separate from its owner for federal tax purposes. |
| 200207018(PDF, 25K) |
1/28/2002 |
| This letter responds to your letter, dated November 1, 2000, and subsequent correspondence, submitted on behalf of Trust, requesting rulings under §§ 61, 661, 1001, and 2601 of the Internal Revenue Code. |
| 200207017(PDF, 11K) |
1/28/2002 |
| This responds to a letter dated October 12, 2001, submitted on behalf of X requesting relief under � 1362(f) of the Internal Revenue Code. |
| 200207016(PDF, 21K) |
1/28/2002 |
| This letter responds to your request, dated October 8, 2001, that we rule on certain tax consequences under � 468A of the Internal Revenue Code of the transfer of Plant 1 and Plant 2 to Genco a limited partnership, and a soon to be created wholly owned subsidiary of Taxpayer. As set forth below, you have requested rulings regarding the tax consequences to the Taxpayer and its qualified nuclear decommissioning funds. |
| 200207015(PDF, 20K) |
1/28/2002 |
| Issues: (1) Whether Taxpayer�s gift tax return failed to show a gift such that the period of limitations is held open pursuant to Internal Revenue Code � 6501(c)(9) with respect to Taxpayer�s gift tax return. (2) Whether Taxpayer�s gift tax return contained a substantial omission such that the period of limitations is held open pursuant to I.R.C. � 6501(e)(2) with respect to Taxpayer�s gift tax return. |
| 200207014(PDF, 9K) |
1/28/2002 |
| This is in reply to a letter dated September 17, 2001 in which rulings are requested with regard to certain federal income tax consequences of a proposed transaction involving the above taxpayers. |
| 200207013(PDF, 12K) |
1/28/2002 |
| This letter is in response to your request for a ruling that the Authority is a political subdivision of Tribe within the meaning of § 7871(d) of the Internal Revenue Code. |
| 200207012(PDF, 37K) |
1/28/2002 |
| Issues: (1) Whether Parent must allocate and apportion its research and development (R&D) expenditures for 1992, 1993, and 1994 to sales on which it pays to FSCsub a commission determined under the administrative pricing rules of � 925(a)(1) or (2) of the Internal Revenue Code, or whether the bonafide cost sharing arrangement that Parent had with CFC1 eliminates the requirement to allocate and apportion Parent's remaining R&D expenditures. Whether this determination must be made before Parent determines its foreign source taxable income under � 861(b), 862(b), and 863(b) for purposes of � 904(a). (2) Whether during a taxable year Parent must use the same method of allocating and apportioning its R&D expenditures for all applicable operative Code sections, including both � 925(a)(1) or (2) of the Code for purposes of determining the FSC commission due FSCsub and � 861(b), 862(b), and 863(b) for purposes of � 904(a). |
| 200207011(PDF, 30K) |
2/7/2002 |
| Issue: Whether Taxpayer's underwriting fees paid to Agent in connection with Facility 1 must be capitalized under § 263 of the Internal Revenue Code? |
| 200207010(PDF, 21K) |
1/28/2002 |
| Issues: (1) Was the bond-financed facility a "qualified hazardous waste facility" as defined in § 142(a)(10) of the Internal Revenue Code? (2) Can a facility, which processes solid hazardous waste, qualify as a "solid waste disposal facility" as defined in § 142(a)(6)? (3) Did the conduit borrower spend bond proceeds on a qualified exempt facility pursuant to § 142(a)? |
| 200207009(PDF, 17K) |
1/28/2002 |
| This letter responds to a letter dated June 6, 2000, and subsequent correspondence, submitted on behalf of P by its authorized representative, requesting rulings under � 29 of the Internal Revenue Code. |
| 200207008(PDF, 6K) |
1/28/2002 |
| This responds to your representative's letter dated May 22, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200207007(PDF, 18K) |
1/28/2002 |
| Issue: Whether the statute of limitations under § 6501(a) is started by the filing of the tax return of the grantor or by the tax return of Grantor Trust. |
| 200207006(PDF, 78K) |
1/28/2002 |
| Issue: What is the appropriate tax treatment of the costs of acquiring assets that Petitioner has called "in-process research and development." |
| 200207005(PDF, 13K) |
2/5/2002 |
| This is in reply to a letter dated April 25, 2001, submitted by your authorized representative, in which a ruling is requested that the transaction described below is not a "modification," as defined in � 424(h) of the Internal Revenue Code. |
| 200207004(PDF, 7K) |
1/25/2002 |
| We received a letter dated April 12, 2001, from Taxpayer's authorized representative requesting permission for Taxpayer to revoke its election under § 41(c)(4) of the Internal Revenue Code. |
| 200207003(PDF, 12K) |
2/5/2002 |
| Issue: Whether, for purposes of the interest allocation rules under Internal Revenue Code � 864(e), a U.S. taxpayer may treat its matched book repurchase agreement ("matched book repo") operation as producing net fee income rather than interest income and interest expense, or alternatively, net the interest income and expense. |
| 200207002(PDF, 6K) |
1/25/2002 |
| This letter is in reply to a letter from your authorized representative, dated March 20, 2001, requesting that we supplement our letter ruling dated March 21, 2000 (PLR-113612- 99) (the "Prior Letter Ruling"). Capitalized terms retain the meaning assigned to them in the Prior Letter Ruling. |
| 200207001(PDF, 9K) |
1/25/2002 |
| This is in response to A�s letter dated May 30, 2001 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. The information submitted for consideration is substantially as set forth below. |
| 200206058(PDF, 44K) |
10/4/2001 |
| We have considered your ruling request regarding the federal income tax consequences of, your participation in a joint venture with individuals and for-profit entities. |
| 200206057(PDF, 42K) |
10/3/2001 |
| This is in reply to your rulings request of March 14, 2001, on P's proposed transfer of all of its assets to Rand S pursuant to � 507(b)(2) of the Internal Revenue Code. |
| 200206056(PDF, 34K) |
10/2/2001 |
| This is in reply to your letter of October 6, 2000, as modified by your letter of November 5, 2001, concerning your proposed merger with and the transfer of your assets to M, a newly established welfare benefit plan. |
| 200206055(PDF, 27K) |
10/1/2001 |
| Issues: (1) Would the Internal Revenue Service be required to provide the taxpayer with a copy of Publication 1 before or at the initial interview with the taxpayer pursuant to the provisions of Internal Revenue Code § 7521(b) with respect to cases developed under the proposed project? (2) If a taxpayer is a non-filer for a particular year would income information for that tax year shown on the Service's Information Reporting Program (IRP) data base constitute a reasonable indication that there is a likelihood of unreported income thereby permitting the use of Financial Status Audit Techniques under � 7602(e)? (3) Would the third-party contact procedures of � 7602(c) apply to the revenue officer and the revenue agent with respect to cases developed under the proposed project? (4) Would the revenue officer be required to inform the taxpayer that a revenue agent is involved in a case developed under the proposed project? |
| 200206054(PDF, 35K) |
9/30/2001 |
| Issues: (1) Whether a taxpayer's requirement that an IRS employee provide personal information before granting access to the audit site interferes with the IRS's ability to set the time and manner of the audit. (2) Whether the employee can use taxpayer issued identification badges for security purposes while auditing the taxpayer on site. |
| 200206053(PDF, 95K) |
9/29/2001 |
| This memorandum is in response to your questions for the public employers' newsletter. It also clarifies an application of the continuing employment exception to the Medicare tax in a factual situation that was not covered in our memo "Employment Tax Issues for Government Entities," which appeared in the June 2000 Employment Tax Update for Government Employers. |
| 200206052(PDF, 5K) |
9/28/2001 |
| This responds to a letter dated August 2, 2001, and subsequent correspondence submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200206051(PDF, 9K) |
9/27/2001 |
| This is in reply to a letter dated May 15, 2001, submitted by X's authorized representative on behalf of X, requesting a ruling that X be given an extension of time to elect to be treated as a disregarded entity for federal tax purposes. |
| 200206050(PDF, 12K) |
9/26/2001 |
| We respond to a letter dated September 10, 2001, submitted on behalf of Parent, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file a statement. The extension is being requested for Parent to file a statement of allowed loss under § 1.1502-20(c) of the Income Tax Regulations (Election), effective for their taxable year ending on Date A. |
| 200206049(PDF, 9K) |
9/25/2001 |
| This ruling responds to a letter submitted on behalf of the Taxpayer by its authorized representatives. The Taxpayer requests an extension of time to file an election to make a mixed straddle account under § 1092(b) of the Internal Revenue Code and § 1.1092(b)-4T(f) of the Temporary Income Tax Regulations for the calendar year ending December 31, Year 1. |
| 200206048(PDF, 9K) |
9/24/2001 |
| This ruling responds to a letter submitted on behalf of the Taxpayer by its authorized representatives. The Taxpayer requests an extension of time to file an election to make a mixed straddle account under § 1092(b) of the Internal Revenue Code and § 1.1092(b)-4T(f) of the Temporary Income Tax Regulations for the calendar year ending December 31, Year 1 with respect to the mixed straddle activities of its Subsidiary. |
| 200206047(PDF, 13K) |
9/23/2001 |
| This is in response to your letter dated July 17, 2001, requesting a ruling that new group annuity contracts issued by Taxpayer are variable contracts within the meaning of � 817(d) of the Internal Revenue Code. |
| 200206046(PDF, 6K) |
9/22/2001 |
| This responds to your representative's letter dated July 16, 2001, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200206045(PDF, 30K) |
9/21/2001 |
| This letter is in response to your authorized representative's submission, dated April 26, 2001, requesting a ruling on the federal estate tax consequences resulting from the proposed appointment in further trust of certain trust property. |
| 200206044(PDF, 32K) |
9/20/2001 |
| This is in response to a request for rulings dated June 20, 2001, submitted on behalf of Coop concerning the proper treatment of the amount received from the sale of stock by Coop. |
| 200206043(PDF, 6K) |
9/19/2001 |
| This responds to your letter dated August 3, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200206042(PDF, 6K) |
9/18/2001 |
| This responds to your letter dated, October 10, 2001, in which you requested relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200206041(PDF, 15K) |
9/17/2001 |
| This letter is in reply to your letter dated October 10, 2001, requesting supplemental rulings regarding the distribution by Distributing to its shareholders of the stock of Controlled, a directly wholly owned subsidiary of Distributing formed on Date 1 (the "Distribution"). |
| 200206040(PDF, 12K) |
9/16/2001 |
| This letter responds to a letter dated September 29, 2001, submitted on behalf of X, requesting a ruling that it be granted an extension of time pursuant to � 301.9100-3 of the Procedure and Administration Regulations in which to elect to be treated as a disregarded entity for federal tax purposes under � 301.7701-3(c). |
| 200206039(PDF, 6K) |
9/15/2001 |
| This letter responds to a letter dated April 3, 2001, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200206038(PDF, 18K) |
9/14/2001 |
| This letter responds to a letter dated D1, and supplemental information, submitted on behalf of Taxpayer requesting a ruling on the appropriate asset class of Rev. Proc. 87-56, 1987-2 C.B. 674, for certain depreciable property which were placed in service by Taxpayer during taxable years D2 and D3. |
| 200206037(PDF, 13K) |
9/13/2001 |
| This letter responds to a letter dated August 31, 2001, submitted on behalf of Taxpayer, requesting a private letter ruling regarding the application of � 42(j) of the Internal Revenue Code to a proposed transfer of bare legal title to certain real property owned by Taxpayer to Authority. |
| 200206036(PDF, 15K) |
9/12/2001 |
| This letter responds to a letter dated September 14, 2001, submitted on behalf of Parent, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file elections. Parent is requesting an extension to file "§ 338 elections" under § 338(g) with respect to Purchaser's acquisition of the stock of Target and the deemed acquisition of the stock of Target Sub 1 through Target Sub 9 (sometimes hereinafter referred to as the "Elections"), on Date C. (All citations in this letter to regulations under § 338 are to regulations in effect on Date C.) |
| 200206035(PDF, 6K) |
9/11/2001 |
| This letter responds to a letter from your authorized representative dated July 19, 2001, as well as subsequent correspondence, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200206034(PDF, 10K) |
9/10/2001 |
| This letter responds to Taxpayer�s request for permission to revoke its election out of the installment method of reporting the gain from three real property sales. This letter ruling is based on the following representations, subject to verification upon audit. |
| 200206033(PDF, 6K) |
9/9/2001 |
| This letter responds to a letter dated June 14, 2001, from your authorized representative, submitted on behalf of Company, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200206032(PDF, 6K) |
9/8/2001 |
| This letter responds to a letter received June 28, 2001, and additional submission, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200206031(PDF, 9K) |
9/7/2001 |
| This letter responds to your letter dated June 6, 2001, as well as subsequent correspondence, requesting a ruling that the rental income received by Company from the Property is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200206030(PDF, 9K) |
9/6/2001 |
| This letter responds to a letter dated July 19, 2001, from your authorized representative, as well as subsequent correspondence, requesting a ruling that the rental income received by Company from the Property is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200206029(PDF, 10K) |
9/5/2001 |
| This is in response to your letter dated August 24, 2001, requesting a ruling on behalf of A under � 877(c) of the Internal Revenue Code of 1986 (the "Code") that A's loss of permanent 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. |
| 200206028(PDF, 9K) |
9/4/2001 |
| We respond to your letter dated July 10, 2001, requesting a ruling supplementing the rulings previously issued in PLR-100524-00 (the Original Letter Ruling). The material information submitted for consideration is summarized below. |
| 200206027(PDF, 10K) |
9/3/2001 |
| This letter responds to a letter dated September 20, 2001, submitted on behalf of Fund. Fund requests that its election under § 855(a) of the Internal Revenue Code to treat dividends distributed after the close of a taxable year as having been paid during that taxable year be considered timely filed pursuant to § 301.9100-3 of the Procedure and Administration Regulations. |
| 200206026(PDF, 8K) |
9/2/2001 |
| This letter responds to your letter submitted on behalf of Company, requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations in which to elect to treat Subsidiary as a Qualified Subchapter S Subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200206025(PDF, 10K) |
9/1/2001 |
| This responds to your representative's request dated June 11, 2001, together with subsequent correspondence, that X be given an extension of time in which to elect to treat its subsidiary as a qualified subchapter S subsidiary under � 1361(b)(3) of the Internal Revenue Code. |
| 200206024(PDF, 23K) |
8/31/2001 |
| This is in response to your letter dated March 12, 2001, requesting a ruling that the Colorado estate tax apportionment statute will apply to apportion taxes among the non-marital and non-charitable beneficiaries of Decedent's will and Trust, as amended. |
| 200206023(PDF, 10K) |
8/30/2001 |
| This letter responds to a letter dated July 5, 2001, from your authorized representative, as well as subsequent correspondence, requesting a ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200206022(PDF, 19K) |
8/29/2001 |
| This letter responds to your letter, dated June 20, 2001, requesting rulings under Internal Revenue Code § 355. Additional information was received in letters dated October 9 and October 30, 2001. |
| 200206021(PDF, 24K) |
8/28/2001 |
| In accordance with § 8.07(2)(a) of Rev. Proc. 2001-1, 2001-1 I.R.B. 1, 43, this Chief Counsel Advice advises you that consent for a change in accounting method has been denied to a taxpayer within your jurisdiction. Pursuant to § 6110 (k)(3), this Chief Counsel Advise is not to be cited as precedent. |
| 200206020(PDF, 19K) |
8/27/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased to be an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective December 6, 2000: |
| 200206019(PDF, 9K) |
8/26/2001 |
| This letter responds to your letter dated June 7, 2001, and subsequent correspondence, written on behalf of X, requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat some of its subsidiaries as qualified subchapter S subsidiaries (QSubs) under § 1361(b)(3) of the Code. |
| 200206018(PDF, 8K) |
8/25/2001 |
| This letter responds to your submission on behalf of Company dated June 28, 2001, requesting a ruling that Company be given an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file a Form 8832 to change its classification pursuant to § 301.7701-3(c) effective for Date 1. |
| 200206017(PDF, 6K) |
8/24/2001 |
| This responds to the letter dated August 17, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200206016(PDF, 8K) |
8/23/2001 |
| This letter responds to a letter dated April 30, 2001, and subsequent correspondence, written on behalf of Taxpayers by their authorized representative requesting that the Service grant Taxpayers an extension of time to make the election under § 469(c)(7)(A) of the Internal Revenue Code and § 1.469-9(g)(3) of the Income Tax Regulations to treat all interests in rental real estate as a single rental real estate activity. |
| 200206015(PDF, 24K) |
8/22/2001 |
| In accordance with § 8.07(2)(a) of Rev. Proc. 2001-1, 2001-1 I.R.B. 1, 43, this Chief Counsel Advice advises you that consent for a change in accounting method has been denied to a taxpayer within your jurisdiction. Pursuant to § 6110 (k)(3), this Chief Counsel Advise is not to be cited as precedent. |
| 200206014(PDF, 43K) |
8/21/2001 |
| Issues: (1) Whether "supervisory goodwill" qualifies as "money or other property" for purposes of § 597 of the Code? (2) Whether Taxpayer properly established a tax basis in the book asset identified as supervisory goodwill? (3) Whether Taxpayer is entitled to claim a deduction for depreciation of supervisory goodwill under § 167 of the Code? |
| 200206013(PDF, 6K) |
8/20/2001 |
| This responds to your letter dated June 21, 2001, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200206012(PDF, 40K) |
8/19/2001 |
| Issues: (1) Whether a taxpayer that uses the dollar-value last-in, first-out (LIFO) method in connection with the retail method is entitled to use the 3-year average method provided by Treasury Regulation § 1.263A-7(c)(2)(v) to compute a § 481(a) adjustment when it changes its method of computing its cost complements under § 1.471-8. (2) Whether the 3-year average method described in Treas. Reg. § 1.263A-7( c)(2)(v) is a method of accounting for purposes of § 446. (3) If the 3 year-average method is a method of accounting, under the cInternal Revenue Codeumstances described below, does its use clearly reflect the taxpayer's income when it values some of the taxpayer's LIFO layers below cost? (4) Whether the Commissioner may challenge the taxpayer's method of revaluing its inventory when the taxpayer revalues its inventory using a method that is specifically provided by the regulations. |
| 200206011(PDF, 10K) |
8/18/2001 |
| This letter responds to your representative�s letter dated August 21, 2001 and supplemental correspondence from your representative requesting a ruling on behalf of Company under Internal Revenue Code �1362(b)(5). |
| 200206010(PDF, 41K) |
8/17/2001 |
| Issues: (1) Whether the Sub A stock received by Branch A as an "interest payment" on the purported loan from Branch A to Sub A should be treated as § 305(a) stock and whether such payment is taxable under United States law. (2) Whether the Taxpayer can claim interest deductions for interest paid with respect to the loan to Taxpayer's branch by the unrelated lenders and the loans to Taxpayer by Sub B and Sub C (as described below), under the assumption that such loans have economic substance. |
| 200206009(PDF, 82K) |
8/16/2001 |
| This Chief Counsel Advice (CCA) responds generally to your office's request of August 8, 2001, that we review and forward to the Tax Division, pursuant to CCDM 34.6.1.3.(2)n, a proposed suit letter requesting that the United States seek an employment tax injunction and other relief against the above-named taxpayer and its principal in a Trust Fund Compliance Initiative (TFCI) case. |
| 200206008(PDF, 63K) |
8/15/2001 |
| Issues: (1) Whether the doctrine of collateral estoppel applies in this case. (2) Whether FCorp 1 should be disregarded as a conduit entity under Treasury Regulation § 1.881-3. |
| 200206007(PDF, 6K) |
8/14/2001 |
| This responds to your letter dated July 9, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200206006(PDF, 101K) |
8/13/2001 |
| Issues: (1) Can each of the two Loans be bifurcated into two pieces, one representing the obligation by the LLCs to pay interest only and one representing the obligation by Sub 2 to pay principal only? (2) Does the Step Transaction Doctrine apply to the facts of this case, with the result that the principal portion of the Loan ($Amount o) is assumed by Sub 2 outside of the § 351 transaction (with the result that there is no gain recognized by the LLCs under § 357(c), no basis increase to Sub 2 under § 362(a), and no loss recognized by Sub 2 on the sale of the Currency b)? (3) Should the transaction at issue be recharacterized in accordance with its substance and Sub 2's loss totally disallowed under § 1.988-2(f)? Alternatively, if the loss is not totally disallowed under § 1.988-2(f), should the loss be recharacterized under § 1.988-1(a)(11)? (4) Can the Commissioner apply § 482 to reallocate the loss from Sub 2 to the LLCs, who are not subject to United States taxation? (5) Whether the overall transaction lacks sufficient economic substance to be respected for federal income tax purposes? |
| 200206005(PDF, 57K) |
8/12/2001 |
| Issues: (1) Whether any part of the amount paid by Taxpayer in redemption of its stock can be deducted as an ordinary and necessary business expense under § 162(a)? (Specifically, whether any part of the amount paid by Taxpayer of the judgment against its directors/shareholders can be deducted as an ordinary and necessary business expense under § 162(a)?) a. If any part of the amount paid can be deducted as an ordinary and necessary business expense, how should the amount be determined? (2) Whether any part of the amount paid by Taxpayer in redemption of its stock can be deducted as interest under § 163? (Specifically, whether any amount paid by Taxpayer for the interest on the judgment against its directors/shareholders can be deducted as an ordinary and necessary business expense under § 162(a)?) a. If any part of the amount paid can be deducted as interest, how should the amount be determined? (3) Whether fees, costs, and other expenditures related to the redemption and bankruptcies can be deducted as ordinary and necessary business expenses under § 162(a)? (Specifically, whether any amount paid by Taxpayer of the legal fees that the directors/shareholders incurred in the initial litigation or the bankruptcy proceedings can be deducted as an ordinary and necessary business expense under § 162(a)?) |
| 200206004(PDF, 6K) |
8/11/2001 |
| This responds to your representative's letter dated June 26, 2001, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200206003(PDF, 29K) |
8/10/2001 |
| Issue: Whether, under the rules of Internal Revenue Code § 83, Company A was entitled to deduct the compensation expenses arising from its officers' filing of � 83(b) elections for their Company B shares. |
| 200206002(PDF, 39K) |
8/9/2001 |
| Issue: How should examination teams close examinations of parties to lease stripping transactions other than the party claiming the main loss that the Service is considering disallowing? |
| 200206001(PDF, 15K) |
8/8/2001 |
| Issue: Whether Bankruptcy Code § 1226(b)(1) forbids the distribution of payments to prepetition creditors under a Chapter 12 plan when administrative expenses accrued and due at the time of the proposed distribution are not paid in full? |
| 200205050(PDF, 28K) |
8/7/2001 |
| This is in response to a letter dated August 22, 2000, as supplemented by additional correspondence dated January 17, 2001, filed on your behalf by your authorized representative regarding a ruling under � 401(a) and 4975(e)(7) of the Internal Revenue Code. The following facts and representations were submitted in support of your request. |
| 200205049(PDF, 65K) |
8/6/2001 |
| This is in reply to your rulings request of March 20, 2001, concerning the proposed transfers by X and by Y of all of their assets to Z pursuant to � 507(b)(2) of the internal Revenue Code. |
| 200205048(PDF, 45K) |
8/5/2001 |
| Issues: (1) P's transfer of its R account assets to R private foundation will not result in a termination of private foundation status under � 507(a) of the Code, but will be an adjustment between private foundations under � 507(b)(2) of the Code. (2) P's transfer of its S account assets to S private foundation will not result in a termination of private foundation status under 507(a) of the Code, but will be an adjustment between private foundations under � 507(b)(2) of the Code. (3) P's transfers of assets are not a notification of P's intent to terminate its status as a private foundation under � 507(a)(l) of the Code. (4) P's transfers of assets will not be a willful and flagrant act (or failure to act) or one of a series of willful repeated acts (or failures to act) giving rise to liability for tax under Chapter 42 of the Code. (5) P's transfers will not subject P, R, or S to any excise tax on net investment income under � 4940 of the Code. |
| 200205047(PDF, 118K) |
8/4/2001 |
| Issues: (1) For personal property located in New Jersey used to secure the � 2057(i)(3)(P) lien, what would be the proper manner to describe such property on the Form 668H? (2) Is the client required to forward to Counsel for legal review each and every � 2057(i)(3)(P) lien filing request? (3) Would a � 2057(i)(3)(P) lien on personal property be enforceable against either a competing creditor who executed and levied upon the asset or a purchaser of the asset, while the � 2057(i)(3)(P) lien was in effect? (4) If personal property subject to a � 2057(i)(3)(P) lien is either sold/transferred or executed and levied upon by a creditor within the 10-year recapture period imposed under Internal Revenue Code § 2032A(c)(1), what would be the effect on the recapture tax? |
| 200205046(PDF, 28K) |
8/3/2001 |
| Issue: Whether the Service is immune from suit when offsets performed pursuant to � 6402(c), (d) or (e) violate the automatic stay. |
| 200205045(PDF, 33K) |
8/2/2001 |
| Issues: (1) Whether interest that accrues on an administrative tax liability incurred during a Chapter 11 reorganization case, prior to a conversion to Chapter 7, is entitled to first priority status in distribution under the Bankruptcy Code after the case is converted. (2) Whether interest continues to accrue on the Chapter 11 administrative tax liability after the case is converted to Chapter 7. |
| 200205044(PDF, 14K) |
8/1/2001 |
| This letter responds to a letter received May 16, 2001, submitted on behalf of Company, requesting a ruling under § 1361(b)(1)(D) of the Internal Revenue Code. |
| 200205043(PDF, 8K) |
7/31/2001 |
| This replies to your letter dated May 1, 2001, submitted on behalf of Taxpayer, requesting an extension of time under Treasury Regulation § 301.9100-3 for Taxpayer to file the statement of election, agreement and certifications required under § 1.1503- 2(g)(2)(i) with respect to the dual consolidated losses of Entities A and B occurring in the taxable year ended on Date A, and to file annual certifications with respect to Entity A's losses incurred in Years X, Y and Z, and Entity B's losses incurred in Year Z that were required to be filed with the tax return for the tax year ended on Date A as required under § 1.1503-2(g)(2)(vi)(B). (Hereinafter the statement of election, agreement and certifications, and the annual certification will be referred to collectively sometimes as "the statements".) |
| 200205042(PDF, 13K) |
7/30/2001 |
| This is in reply to a letter dated October 2, 2001, requesting rulings on behalf of Fund. Fund requests a ruling granting permission for calendar year 2001 and subsequent calendar years to revoke an election under § 4982(e)(4)(A) of the Internal Revenue Code to use Fund's tax year (the calendar year) in lieu of the 1-year period ending October 31, for purposes of calculating the required distribution amount under § 4982(b)(1)(B), § 4982(e)(2), § 4982(e)(5), and § 4982(e)(6). Further, Fund requests a ruling that in calculating the required distribution under § 4982 for the calendar year ending December 31, 2001, Fund's capital gain net income shall be determined on the basis of capital gains and losses realized and recognized during the 10-month period beginning on January 1, 2001, and ending on October 31, 2001; and its ordinary income shall be determined by including foreign currency gains and losses attributable to transactions under § 988 that are properly taken into account for the 10-month period beginning on January 1, 2001, and ending on October 31, 2001. |
| 200205041(PDF, 6K) |
7/29/2001 |
| This private ruling letter responds to your letter, dated July 10, 2001, submitted on behalf of X, requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200205040(PDF, 14K) |
7/28/2001 |
| This letter responds to your request, dated May 1, 2001, requesting rulings under § 301.9100-1 of the Procedure and Administration Regulations as well as rulings under § 2632 and § 2642 of the Internal Revenue Code. |
| 200205039(PDF, 6K) |
7/27/2001 |
| This responds to your letter dated September 7, 2001, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200205038(PDF, 6K) |
7/26/2001 |
| This responds to a letter dated August 10, 2001, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200205037(PDF, 14K) |
7/25/2001 |
| This letter responds to a letter dated September 13, 2001, submitted on behalf of Purchaser, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser is requesting an extension to file a "§ 338 election" under § 338(g) and § 1.338-2T(d) with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date B. (All citations in this letter to regulations under § 338 are to regulations in effect on Date B.) |
| 200205036(PDF, 8K) |
7/24/2001 |
| This responds to your letter dated September 28, 2001, submitted on behalf of X, requesting an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations to elect to treat Y as a qualified S subsidiary for federal tax purposes. |
| 200205035(PDF, 14K) |
7/23/2001 |
| This letter responds to a letter dated May 25, 2001, requesting rulings supplementing our prior letter ruling dated March 14, 2001 (PLR-111625-01) (the "Original Ruling") and a supplemental letter ruling dated May 17, 2001 (PLR-121115- 01)(the "First Supplemental Ruling," and, together with the Original Ruling, the "Prior Rulings"). |
| 200205034(PDF, 18K) |
7/22/2001 |
| This letter responds to your letter dated May 7, 2001, in which rulings were requested as to the federal income tax consequences of a proposed transaction. Additional information was received in letters dated July 27, August 16, and October 31, 2001. |
| 200205033(PDF, 10K) |
7/21/2001 |
| This letter is in reply to your letter of May 15, 2001, requesting a ruling that trust property over which Decedent had powers of appointment will not be included in Decedent's gross estate under � 2041(a)(1) of the Internal Revenue Code. |
| 200205032(PDF, 6K) |
7/20/2001 |
| This responds to a letter dated July 20, 2001, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200205031(PDF, 22K) |
7/19/2001 |
| Issue: Whether the transaction, in which Parent purchased through a prepaid purchase agreement a security issued by its Country A subsidiary to two unrelated foreign banks, may be recharacterized for federal income tax purposes. |
| 200205030(PDF, 19K) |
7/18/2001 |
| In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased to be an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective December 29, 2000. |
| 200205029(PDF, 6K) |
7/17/2001 |
| This responds to your letter dated, September 23, 2001 in which you requested relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200205028(PDF, 10K) |
7/16/2001 |
| This letter responds to your August 2, 2001 request for a ruling on behalf of Company regarding the proper treatment of income recognized from the sale of certain Minerals during the 10-year recognition period under § 1374 of the Internal Revenue Code of 1986, as amended . |
| 200205027(PDF, 27K) |
7/15/2001 |
| Issue: Whether the fraud of Taxpayer's Husband in valuing a gift can be used as the basis for holding the period of limitations open pursuant to Internal Revenue Code § 6501(c)(1) with respect to Taxpayer's gift tax return when Taxpayer's Husband and Taxpayer elect split gift treatment under I.R.C. § 2513. |
| 200205026(PDF, 6K) |
7/14/2001 |
| This responds to a letter dated May 31, 2001, submitted by A, X's president, on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200205025(PDF, 8K) |
7/13/2001 |
| This letter is in response to your request for a written determination, dated July 26, 2001, and submitted on behalf of LLC, requesting an extension of time to make an election under � 754 of the Internal Revenue Code. |
| 200205024(PDF, 12K) |
7/12/2001 |
| This responds to your letter dated October 30, 2000, and subsequent correspondence, submitted on behalf of Company, requesting inadvertent termination relief under � 1362(f) of the Internal Revenue Code. |
| 200205023(PDF, 61K) |
7/11/2001 |
| Issues: (1) Whether the Lease-in/Lease-out (LILO) transaction described below has economic substance. (2) Whether the LILO transaction qualifies for nonrecognition treatment under � 1031 of the Internal Revenue Code. (3) Whether A is required to include in income original Issue: discount. (4) Whether A's participation in the LILO transaction subjects it to the accuracy-related penalty for negligence and substantial understatement pursuant to � 6662. |
| 200205022(PDF, 11K) |
7/10/2001 |
| This letter responds to a letter dated June 25, 2001, and subsequent correspondence, requesting on behalf of Company an extension of time pursuant to §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations for Company to elect to treat Subsidiary as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. Company and Subsidiary's shareholders also requested an extension of time pursuant to §§ 301.9100-1 through 301.9100-3 to file a § 338(h)(10) election under §§ 338(g) and 338(h)(10). |
| 200205021(PDF, 20K) |
7/9/2001 |
| Issues: (1) Whether the partnership anti-abuse regulation, Treasury Regulation § 1.701-2(e), is applicable to treat transactions between USCorpA and FPtnrshipA/B as transactions between USCorpA and FPtnrshipA/B's foreign partners. (2) Whether and how � 482 of the Internal Revenue Code applies to allocate income to USCorpA from FPtnrshipA/B in connection with USCorpA's Project A development activities. |
| 200205020(PDF, 6K) |
7/8/2001 |
| This responds to your representative's letter dated June 22, 2001, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200205019(PDF, 9K) |
7/7/2001 |
| This letter responds to a letter dated July 25, 2001, submitted on behalf of X, requesting a ruling that X's rental income from its commercial rental properties is not passive investment income within the meaning of §1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200205018(PDF, 14K) |
7/6/2001 |
| This letter responds to a letter dated July 18, 2001, submitted on behalf of Corp1, requesting an extension of time under §§301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Corp1 is requesting an extension to file a "§ 338 election" under § 338(g) with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date B. (All citations in this letter to regulations under § 338 are to regulations in effect on Date B.) |
| 200205017(PDF, 14K) |
7/5/2001 |
| This letter responds to a letter dated July 18, 2001, submitted on behalf of Corp1, requesting an extension of time under §§301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Corp1 is requesting an extension to file a "§ 338 election" under § 338(g) with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date B. (All citations in this letter to regulations under § 338 are to regulations in effect on Date B.) |
| 200205016(PDF, 13K) |
7/4/2001 |
| This letter responds to a letter dated July 18, 2001, submitted on behalf of Corp1, requesting an extension of time under §§301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Corp1 is requesting an extension to file a "§ 338 election" under § 338(g) with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date B. (All citations in this letter to regulations under § 338 are to regulations in effect on Date B.) |
| 200205015(PDF, 14K) |
7/3/2001 |
| This letter responds to a letter dated July 18, 2001, submitted on behalf of Corp1, requesting an extension of time under §§301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Corp1 is requesting an extension to file a "§ 338 election" under § 338(g) with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date B. (All citations in this letter to regulations under § 338 are to regulations in effect on Date B.) |
| 200205014(PDF, 7K) |
7/2/2001 |
| This is in reply to a letter dated April 27, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling that X be given an extension of time to elect to be classified as a partnership for federal tax purposes. |
| 200205013(PDF, 13K) |
7/1/2001 |
| This letter responds to a letter dated July 18, 2001, submitted on behalf of Corp1, requesting an extension of time under §§301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Corp1 is requesting an extension to file a "§ 338 election" under § 338(g) with respect to Purchaser's acquisition of the stock of Target (sometimes hereinafter referred to as the "Election"), on Date B. (All citations in this letter to regulations under § 338 are to regulations in effect on Date B.) |
| 200205012(PDF, 5K) |
6/30/2001 |
| This responds to a letter dated July 10, 2001, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200205011(PDF, 6K) |
6/29/2001 |
| This responds to a letter dated July 31, 2001, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200205010(PDF, 6K) |
6/28/2001 |
| This letter responds to your request for a private letter ruling, dated June 29, 2001, submitted on behalf of X, requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200205009(PDF, 19K) |
6/27/2001 |
| This is in response to your request for a ruling that the Agreement as described below is a management contract that meets the requirements of Revenue Procedure 97-13, 1997-1 C.B. 632. |
| 200205008(PDF, 22K) |
6/26/2001 |
| This responds to your letter dated October 19, 2000, and subsequent correspondence, submitted on behalf of Trust and Donor, requesting rulings under §§ 170, 2522, and 664 of the Internal Revenue Code on the income and gift tax consequences of the contribution of a portion of an interest in a trust (Trust) to a charitable remainder beneficiary of Trust. |
| 200205007(PDF, 9K) |
6/25/2001 |
| This is in response to your letter of April 11, 2001 and subsequent correspondence requesting a ruling with respect to X's Deferred Compensation Plan which X intends to be an eligible deferred compensation plan under � 457 of the Internal Revenue Code of 1986. |
| 200205006(PDF, 6K) |
6/24/2001 |
| This responds to a letter dated June 25, 2001, together with subsequent correspondence, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200205005(PDF, 8K) |
6/23/2001 |
| This letter responds to a letter dated February 22, 2001, written on behalf of X, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election under § 301.7701-3(c). |
| 200205004(PDF, 12K) |
6/22/2001 |
| This letter responds to a letter dated May 1, 2001, and subsequent correspondence, submitted on behalf of Company requesting a ruling under § 1362(f) of the Internal Revenue Code. |
| 200205003(PDF, 52K) |
6/21/2001 |
| Issues: (1) Whether Internal Revenue Code § 269(a)(2) can be applied to disallow any loss by D on the sale or disposition of worthless properties. (2) Whether, upon D's abandonments of "worthless" C-contributed properties, � 482 permits the Service to make appropriate primary and correlative allocations (to D and C, respectively) and conforming adjustments (to the basis of C's D APS) to prevent the replication of losses that had effectively been sustained as of the time of the � 351 transfer. |
| 200205002(PDF, 35K) |
6/20/2001 |
| Issue: To what extent are assets that were not reported on the estate tax returns filed for the estates of Decedent and Decedent's pre-deceased spouse, A, includible in Decedent's gross estate? |
| 200205001(PDF, 16K) |
6/19/2001 |
| This letter responds to your December 20, 2000 request for rulings on certain federal income tax consequences of a proposed transaction. |
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