2004 Chief Counsel's
Written Determinations
200410000 to 200414999
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.
| 200414050(PDF, 162K) |
4/9/2004 |
| This is in response to a letter dated November 4, 2003, from rs authorized representative, who has requested rulings to confirm that the intellectual property owned by and licensed to the publicly supported charity constitutes an asset used directly in carrying out the rs exempt purpose and, as such, the fair market value of the intellectual property is excludable from the rs minimum investment return base under section 4942 of the Internal Revenue Code. |
| 200414049(PDF, 228K) |
4/9/2004 |
| This letter is in response to a request for a private letter ruling dated August 6, 2003, as supplemented by correspondence dated December 22, 2003, submitted on your behalf by your authorized representative in which you request relief under section 301.9100-3 of the Procedure and Administration Regulations. Specifically, your request for relief relates to the filing of the election provided for in section 3 of Revenue Procedure 93-40, 1993-2 C.B. 535 ("Rev. Proc. 93-40") to be treated as operating qualified separate lines of business ("QSLOBs") under section 414 (r) (2) of the Internal Revenue Code of 1986, as amended. |
| 200414048(PDF, 420K) |
1/5/2004 |
| In a letter dated November 3, 2003, your authorized representative requested rulings on your behalf concerning the distribution restrictions under Section 1.401 (a)(4)-5(b)(3) of the Income Tax Regulations. |
| 200414047(PDF, 175K) |
1/5/2004 |
| This is in response to a ruling request dated November 5, 2003, as supplemented by additional correspondence dated December 9,2003, from your authorized representative, in which you request relief under sections 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations (�Regulations�). |
| 200414046(PDF, 87K) |
4/2/2004 |
| This memorandum is in response to your request for advice. In accordance with section 6110(k)(3) of the Internal Revenue Code, this document should not be cited as precedent. We are continuing to examine the issues raised herein. Accordingly, we may issue supplemental advice regarding this case at a future date. |
| 200414045(PDF, 39K) |
4/2/2004 |
| Issue: May the Service initiate a TETRA partnership proceeding for Year 1 when the period for assessment has expired for all partners for Year 1, but the partners may have claimed losses attributable to Year 1 partnership items in subsequent open years? |
| 200414044(PDF, 20K) |
4/2/2004 |
| This letter responds to a letter dated August 21, 2003, and subsequent correspondence submitted on behalf of X, requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200414043(PDF, 33K) |
4/2/2004 |
| This responds to your request for a ruling dated October 17, 2003, and supplemental correspondence dated December 11, 2003, submitted on behalf of Fund. Fund requests a ruling that it will not recognize gain or loss under section 852(b)(6) of the Internal Revenue Code of 1986 upon the distribution of stock or other securities in redemption of shares of Fund upon the request of a shareholder pursuant to a tender offer. |
| 200414042(PDF, 24K) |
4/2/2004 |
| This letter responds to a letter dated June 24, 2002, and subsequent correspondence submitted on behalf of X, requesting a ruling under�1362(b)(5) of the Internal Revenue Code. |
| 200414041(PDF, 19K) |
4/2/2004 |
| This responds to a letter dated October 30, 2003, and subsequent correspondence, submitted on behalf of X, requesting relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200414040(PDF, 19K) |
4/2/2004 |
| This responds to a letter dated October 8, 2003, and subsequent correspondence, submitted on behalf of X, requesting relief under section 1362(b)(5) of the Internal Revenue Code. |
| 200414039(PDF, 40K) |
4/2/2004 |
| This is in response to your authorized representative's letter and submissions of July 15, 2003, and other correspondence and submissions, in which you, X, (sometimes referred to herein as the Seminary) requested certain rulings regarding the proper federal income tax treatment (including any reporting and/or withholding obligations) for grants to be awarded under the M scholarship program, as further described herein. We are pleased to address your concerns. |
| 200414038(PDF, 33K) |
4/2/2004 |
| This letter responds to a letter from your authorized representative dated August 15, 2003, as well as subsequent correspondence, submitted on behalf of Company, requesting a ruling that the rental income received by Company from Property 1 through Property 36 (the Properties) is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200414037(PDF, 41K) |
4/2/2004 |
| This letter responds to your August 8, 2003 request for rulings on certain federal income tax consequences of a proposed transaction. The information submitted in that letter and in subsequent correspondence is summarized below. |
| 200414036(PDF, 31K) |
4/2/2004 |
| This letter responds to a letter dated October 27, 2003, submitted on behalf of Parent requesting an extension of time under�301.9100-3 of the Procedure and Administration Regulations to file a statement. Parent is requesting an extension of time to file a statement under � 1.337(d)-2T(c) of the Income Tax Regulations (the �Statement�) with respect to Parent�s basis adjustment in its Subsidiary stock in connection with the issuance of X shares of Subsidiary stock to Company on Date A (�Stock Issuance�). Additional information was received in a letter dated December 11, 2003. The material information is summarized below. |
| 200414035(PDF, 23K) |
4/2/2004 |
| This responds to a letter from X�s authorized representative dated August 12, 2003, requesting that the Service grant X an extension of time to elect to be treated as a disregarded entity under � 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200414034(PDF, 27K) |
4/2/2004 |
| This is in response to your letters dated April 30, 2003, and November 12, 2003, on behalf of Taxpayer requesting a ruling under section 877(c) of the Internal Revenue Code of 1986 that the relinquishment of her United States 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. The information submitted for consideration is substantially as set forth below. |
| 200414033(PDF, 18K) |
4/2/2004 |
| This responds to your letter dated, December 19, 2002 in which you requested relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200414032(PDF, 28K) |
4/2/2004 |
| This is in response to letters from your authorized representative dated May 8, 2003, and October 29, 2003, on your behalf requesting a ruling under section 877(c) of the Internal Revenue Code of 1986 that your loss of U.S. 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. The information submitted for consideration is substantially as set forth below. |
| 200414031(PDF, 39K) |
4/2/2004 |
| We reply to your letter dated August 7, 2003, requesting rulings as to the federal income tax consequences of a proposed transaction. Additional information was submitted in a letter dated November 20, 2003. The information submitted for consideration is summarized below. |
| 200414030(PDF, 29K) |
4/2/2004 |
| This replies to a letter dated October 15, 2002, in which Taxpayer requests an extension of time under Treas. Reg. � 301.9100-3 to file the agreement described in � 1.1503-2(g)(2)(i) in accordance with Exhibit A, which is attached and made a part of this ruling letter. The information submitted for consideration is substantially as set forth below. |
| 200414029(PDF, 22K) |
4/2/2004 |
| This responds to a letter dated September 30, 2003, and subsequent correspondence, submitted on behalf of X, requesting relief under�1362(b)(5) of the Internal Revenue Code. |
| 200414028(PDF, 24K) |
4/2/2004 |
| This letter responds to a letter dated August 6, 2003, written on behalf of X and A, requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations, that A be granted an extension of time to elect to be treated as a disregarded entity under section 301.7701-3(c). |
| 200414027(PDF, 62K) |
4/2/2004 |
| This letter responds to Taxpayer�s authorized representative�s letter dated September 3, 2003, submitted on behalf of Taxpayer, requesting a letter ruling concerning whether the transfer of an intertie by Generator to Taxpayer will be a nonshareholder contribution to capital excludable from income under�118(a) of the Internal Revenue Code. |
| 200414026(PDF, 20K) |
4/2/2004 |
| This responds to the letter dated August 13, 2003, and related correspondence, submitted on behalf of X, requesting relief under�1362(b)(5) of the Internal Revenue Code. |
| 200414025(PDF, 37K) |
4/2/2004 |
| This is in reply to a letter dated August 15, 2003, and subsequent submission, requesting a ruling on behalf of Taxpayer. You have requested a ruling that a �Guarantor Substitution Payment�, as described below, is not includible in Taxpayer�s gross income for purposes of the gross income tests under sections 856(c)(2) and (c)(3) of the Internal Revenue Code. |
| 200414024(PDF, 22K) |
4/2/2004 |
| This letter responds to your letter dated September 22, 2003, and subsequent correspondence written on behalf of X, requesting a ruling under�1362(b)(5) of the Internal Revenue Code. |
| 200414023(PDF, 51K) |
4/2/2004 |
| This letter is in reply to your letter dated July 23, 2003, requesting rulings as to the federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated October 3, October 14, October 30, November 20, December 8, and December 10, 2003. The information submitted for consideration is summarized below. |
| 200414022(PDF, 22K) |
4/2/2004 |
| This letter responds to your letter dated August 29, 2003, which requests rulings on certain federal income tax consequences of a consummated transaction. The material information submitted for consideration is summarized below. |
| 200414021(PDF, 23K) |
4/2/2004 |
| This letter responds to the Issuer�s request for a ruling that certain bonds to be issued pursuant to the Program (the �Program Bonds�), as administered under State law effective on Date 1, will be described in the Provision. |
| 200414020(PDF, 19K) |
4/2/2004 |
| This responds to a letter dated April 12, 2003, submitted on behalf of X, requesting a ruling under�1362(b)(5) of the Internal Revenue Code. |
| 200414019(PDF, 28K) |
4/2/2004 |
| This is in response to your letter dated August 15, 2003, submitted on behalf of Coop requesting a ruling on the federal income tax consequences of a transaction as described below. |
| 200414018(PDF, 36K) |
4/2/2004 |
| This letter responds to your July, 30, 2003, request for rulings regarding certain federal income tax consequences of a proposed transaction. The facts submitted for consideration are substantially as set forth below. |
| 200414017(PDF, 20K) |
4/2/2004 |
| This responds to your letter dated August 14, 2003, and subsequent correspondence submitted on behalf of X, requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200414016(PDF, 28K) |
4/2/2004 |
| This letter responds to a letter, dated Date 1, submitted on behalf of A by A�s authorized representative, requesting certain rulings under the Internal Revenue Code. |
| 200414015(PDF, 73K) |
4/2/2004 |
| This letter replies to your August 6, 2003 letter on behalf of Distributing 2 requesting rulings as to certain federal income tax consequences of a series of proposed transactions. Following is a summary of the information in your letter and subsequent correspondence. |
| 200414014(PDF, 26K) |
4/2/2004 |
| This responds to a letter dated September 9, 2003, and subsequent correspondence, submitted by X�s authorized representative on behalf of X, requesting a ruling that X be given an extension of time to elect under � 301.9100-3 of the Procedure and Administration Regulations to be classified as an association taxable as a corporation for federal tax purposes and to be treated as an S corporation under � 1362(b)(5) of the Internal Revenue Code. |
| 200414013(PDF, 31K) |
4/2/2004 |
| This responds to a letter dated August 4, 2003, and subsequent correspondence, submitted by X�s authorized representative on behalf of X, requesting a ruling on the federal income tax consequences of the conversion of X from a general partnership into a limited liability company (LLC). |
| 200414012(PDF, 30K) |
4/2/2004 |
| This responds to a letter dated June 18, 2003, and subsequent correspondence submitted on behalf of X by its authorized representative, requesting relief under � 1362(f) of the Internal Revenue Code. |
| 200414011(PDF, 45K) |
4/2/2004 |
| This letter responds to your letter dated January 29, 2003, and subsequent correspondence, submitted on behalf of the Estate as its authorized representative, requesting rulings under '' 664 and 2055 of the Internal Revenue Code. |
| 200414010(PDF, 61K) |
4/2/2004 |
| This is in response to a letter dated December 30, 2002, and subsequent correspondence, requesting rulings regarding the income, gift, and generation-skipping transfer tax consequences of the proposed division of a trust. |
| 200414009(PDF, 21K) |
4/2/2004 |
| This responds to a letter dated July 22, 2003, submitted on behalf of X by its authorized representative, requesting a ruling under�1362(b)(5) of the Internal |
| 200414008(PDF, 44K) |
4/2/2004 |
| This letter responds to a letter dated July 18, 2003, and supplemental correspondence, requesting an extension of time pursuant to�301.9100-3 of the Procedure and Administration Regulations for Taxpayer to make a qualified progress expenditure election under section 47(d)(5) of the Internal Revenue Code. |
| 200414007(PDF, 33K) |
4/2/2004 |
| This is in response to a request for rulings dated July 28, 2003, and subsequent correspondence, submitted by Taxpayer�s authorized representative concerning proposed amendments to Taxpayer�s employee stock option plans. The proposed amendments will allow employees holding options to transfer them to an unrelated third party in exchange for cash and a deferred payment obligation. |
| 200414006(PDF, 29K) |
4/2/2004 |
| This letter responds to a letter dated October 16, 2002, requesting an extension of time pursuant to�301.9100-3 of the Procedure and Administration Regulations for Taxpayer to file an application for certification of historic status with the United States Department of Interior. |
| 200414005(PDF, 31K) |
4/2/2004 |
| This letter responds to a letter dated May 12, 2003, requesting an extension of time pursuant to�301.9100-3 of the Procedure and Administration Regulations for Taxpayer to file an application for certification of historic status with the United States Department of Interior. |
| 200414004(PDF, 35K) |
4/2/2004 |
| This letter responds to a letter dated July 1, 2003, and subsequent correspondence written on behalf of X by its authorized representative, requesting a ruling under � 1362(f) of the Internal Revenue Code. |
| 200414003(PDF, 24K) |
4/2/2004 |
| This letter responds to a letter dated August 6, 2003, written on behalf of X and A, requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations, that A be granted an extension of time to elect to be treated as a disregarded entity under section 301.7701-3(c). |
| 200414002(PDF, 37K) |
4/2/2004 |
| This is in response to your letter dated June 27, 2003, requesting an extension of time pursuant to � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make allocations of Taxpayer�s generation-skipping transfer tax exemption. |
| 200414001(PDF, 35K) |
4/2/2004 |
| This letter responds to your November 18, 2003 request for a ruling on certain federal income tax consequences of a proposed transaction. The information submitted in that request and in later correspondence is summarized below. |
| 200413015(PDF, 130K) |
3/26/2004 |
| This is in reply to your rulings request of December 12, 2001, concerning P's proposed transfer of endowment funds to its own supporting organization S. |
| 200413014(PDF, 230K) |
3/26/2004 |
| This letter is in response to your ruling request under section 4958 of the Internal Revenue Code. |
| 200413013(PDF, 171K) |
3/26/2004 |
| This is in reply to a request for a ruling dated November 25, 2002 concerning the tax consequences of a transfer of assets from one voluntary employees' beneficiary association to another voluntary employees' beneficiary association. |
| 200413012(PDF, 35K) |
3/26/2004 |
| Issue: For purposes of the �5 percent rule� (see below) under � 1.148-6(d)(3)(iii) of the Income Tax Regulations, does the �actual working capital expenditures of the issuer in the prior fiscal year� include expenditures made from amounts that in the prior fiscal year were restricted to use for expenditures other than working capital expenditures of the type financed. |
| 200413011(PDF, 66K) |
3/26/2004 |
| This letter is in response to the November 7, 2003, letter submitted by your authorized representative on your behalf, and prior submissions, in which you request rulings as to the qualification of a transfer to a trust for a marital deduction under section 2523(f) of the Internal Revenue Code and the subsequent includibility of the transferred property in the gross estate of Taxpayer or Spouse at their deaths. |
| 200413010(PDF, 38K) |
3/26/2004 |
| This letter is in response to your request on behalf of the State for a ruling that the Registered Warrants will be �obligations� of the State for purposes of � 103 of the Internal Revenue Code. |
| 200413009(PDF, 26K) |
3/26/2004 |
| This letter responds to a letter from your authorized representative dated August 13, 2003, as well as subsequent correspondence, submitted on behalf of Company, 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. |
| 200413008(PDF, 25K) |
3/26/2004 |
| This letter responds to your letter dated July 7, 2003, as well as subsequent correspondence, submitted on behalf of Company, 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. |
| 200413007(PDF, 23K) |
3/26/2004 |
| This is in reply to a request for a ruling on behalf of the ----, ---- exempt from tax under section 501(c)(6) of the Internal Revenue Code , concerning whether Plan would continue to meet the requirements of section 457(e)(12) of the Code, and continue to be excepted from section 457 of the Code, following the proposed amendment to the Plan as described below. |
| 200413006(PDF, 23K) |
3/26/2004 |
| This letter responds to the letter dated July 17, 2003 and related correspondence, written on behalf of X, requesting an extension of time under�301.9100-1 and�301.9100-3 of the Procedure and Administration Regulations to file an entity classification election under � 301.7701-3(c). |
| 200413005(PDF, 46K) |
3/26/2004 |
| This letter responds to a letter, dated June 23, 2003, and subsequent correspondence, submitted on behalf of P by its authorized representative, requesting rulings under section 29 of the Internal Revenue Code. |
| 200413004(PDF, 71K) |
3/26/2004 |
| This letter responds to a letter, dated April 15, 2003 and subsequent correspondence, submitted on behalf of P by its authorized representative, requesting rulings under section 29 of the Internal Revenue Code. |
| 200413003(PDF, 32K) |
3/26/2004 |
| This responds to a ruling request submitted on behalf of Trust February 24, 2003, by your authorized representatives, requesting an extension of time pursuant to ''301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations for REMIC to make an election under �860(D)(b)(1) of the Internal Revenue Code of 1986 and �1.860D-1(d) of the Income Tax Regulations to be treated as a Real Estate Mortgage Investment Conduit (REMIC) for Year 1 and subsequent taxable years. |
| 200413002(PDF, 21K) |
3/26/2004 |
| This letter responds to your letter dated January 31, 2003, and supplemental correspondence, requesting a ruling under � 301.9100-3(a) of the Procedure and Administration Regulations that Taxpayer be granted an extension of time to make an election to be treated as a partnership for federal income tax purposes. |
| 200413001(PDF, 25K) |
3/26/2004 |
| That upon execution of the Trust agreement and the transfer of the Trust assets thereto, the Trust will be a qualified settlement fund under section 1.468B-1(a) of the Income Tax Regulations. |
| 200412002(PDF, 137K) |
3/18/2004 |
| This is in response to a request submitted on your behalf by your authorized representative by letter dated September 17, 2003, for a ruling to waive the 60-day rollover requirement contained in section 402(c)(3)(8) of the Internal Revenue Code . |
| 200412001(PDF, 159K) |
3/18/2004 |
| This is response to a letter dated August 20, 2003, as supplemented by letters dated November 19, 2003, December 12, 2003, and December 15,2003, submitted on your behalf by your authorized representative, in which you request relief under section 301.9100-3 of the Procedure and Administration Regulations (the "Regulations"). |
| 200410028(PDF, 248K) |
3/5/2004 |
| Specifically, you have asked whether contributions of $1,488,503 to the Plan, that were made for the plan year ended August 31, 2001, are fully deductible under �� 404(a) and 413(b)(7) of the Code. |
| 200410027(PDF, 114K) |
3/5/2004 |
| This is in response to a ruling request submitted, in which you request a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200410026(PDF, 129K) |
3/5/2004 |
| This is in response to a ruling request dated February 5, 2003, as supplemented by additional information submitted April 2, 2003, concerning the pick up of employee contributions to Plan X under section 414(h)(2) of the Internal Revenue Code. |
| 200410025(PDF, 267K) |
3/5/2004 |
| Ruling request concerning the federal income tax treatment of certain contributions to System S under section 414(h)(2) of the Internal Revenue Code. |
| 200410024(PDF, 311K) |
3/5/2004 |
| This is in response to your request for a private letter ruling, dated November 26, 2002, as supplemented by letters dated January 16 and 20, 2003, May 19,2003, and October 2 and 23, 2003, concerning the applicability of section 41 5(m) of the Internal Revenue Code to an excess plan and the tax consequences of certain related transactions. |
| 200410023(PDF, 261K) |
3/5/2004 |
| Requested several letter rulings under sections 402(e)(4)(B) and 72(t)(2)(A) of the Internal Revenue Code. |
| 200410022(PDF, 223K) |
3/5/2004 |
| This is in response to your request for a private letter ruling, dated May 2, 2003, as supplemented by letters dated June 10. July 23, September 19 and 30, October 29 and November 3 and 5, 2003 concerning the applicability of section 41 5(m) of the Internal Revenue Code to Excess Plan B. |
| 200410021(PDF, 288K) |
3/5/2004 |
| Request for letter rulings under section 401(a)(9) of the Internal Revenue Code. |
| 200410020(PDF, 282K) |
3/5/2004 |
| Request for letter rulings under section 401(a)(9) of the Internal Revenue Code. |
| 200410019(PDF, 285K) |
3/5/2004 |
| Request for letter rulings under section 401(a)(9) of the Internal Revenue Code. |
| 200410018(PDF, 199K) |
3/2/2004 |
| Request for a private letter ruling, submitted on your behalf by your authorized representative, concerning whether Plan X is a governmental plan under section 414(d) of the Code . |
| 200410017(PDF, 217K) |
3/5/2004 |
| Request for a private letter ruling, as supplemented by correspondence, submitted on your behalf by your authorized representative, concerning whether Plan X is a governmental plan under section 414(d) of the Code. |
| 200410016(PDF, 221K) |
3/5/2004 |
| Request for a private letter ruling dated ***, as supplemented by correspondence dated ***, *** and ***, submitted on your behalf by your authorized representative, concerning whether Plan X is a governmental plan under section 414(d) of the Code. |
| 200410015(PDF, 163K) |
3/5/2004 |
| Requesting rulings under �� 2041 and 2601 of the Code. |
| 200410014(PDF, 117K) |
3/5/2004 |
| Requesting rulings under �� 2036, 2038, 2041, and 2601 of the Code. |
| 200410013(PDF, 94K) |
3/5/2004 |
| Request for rulings regarding certain federal income tax consequences of a proposed transaction. |
| 200410012(PDF, 25K) |
3/5/2004 |
| Requested a ruling that premiums received by the Taxpayer on policies of insurance or reinsurance of U.S. risks are exempt from the insurance excise tax imposed by � 4371 of the Code of 1986, as amended, pursuant to the Treaty, and to letters dated June 26, and August 27, in which you furnished additional information. |
| 200410011(PDF, 32K) |
3/5/2004 |
| Requesting on your behalf an extension of time under 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make a qualified terminable interest property ("QTIP") election under � 2056(b)(7) of the Code. |
| 200410010(PDF, 33K) |
3/5/2004 |
| Requested a ruling that in the situations described below, Taxpayer's share of otherwise qualifying income will not be excluded from �rents from real property� pursuant to section 856(d)(2)(C) of the Code. |
| 200410009(PDF, 34K) |
3/5/2004 |
| Request for rulings concerning the Federal income tax consequences of a proposed transaction. Additional information was submitted in letters dated October 29, and November 24, 2003. |
| 200410008(PDF, 41K) |
3/5/2004 |
| Requesting rulings regarding the GST tax consequences of the proposed division of and modifications to Trust. |
| 200410007(PDF, 19K) |
3/5/2004 |
| Request for a ruling concerning the federal tax treatment under section 104(a)(1) of the Code of benefits received by firefighters from the Plan. |
| 200410006(PDF, 41K) |
3/5/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations and� 2642(g)(1) of the Code to make allocations of GST tax exemption. |
| 200410005(PDF, 31K) |
3/5/2004 |
| Request for a letter ruling concerning the applicability of the Medicare tax exemption contained in section 3121(u)(2)(C) of the Code to certain firefighters and police officers subsequent to the consolidation of Political Subdivision 1 and Political Subdivision 2 and the creation of Political Subdivision 3. |
| 200410004(PDF, 16K) |
3/5/2004 |
| Request on behalf of the System concerning whether disability benefits paid under the Statute are excludable from the gross income of recipients under section 104(a)(1) of the Code . |
| 200410003(PDF, 37K) |
3/5/2004 |
| Request for rulings submitted on behalf of Distributing regarding certain federal income tax consequences of a proposed transaction. |
| 200410002(PDF, 25K) |
3/5/2004 |
| Issue: Whether promissory notes that were issued by a family-owned business constitute a qualified family-owned business interest (QFOBI) that is deductible by an estate under section 2057 of the Code? |
| 200410001(PDF, 21K) |
3/5/2004 |
| Request that we supplement our letter ruling dated May 14, 2002 (PLR-102683-02) (the �Prior Letter Ruling�). |
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