| 200504042(PDF, 176K) |
11/1/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200504041(PDF, 235K) |
11/2/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200504040(PDF, 330K) |
11/4/2004 |
| Requesting a ruling letter concerning the prepayment of an exempt loan upon termination of an employee stock ownership plan. |
| 200504039(PDF, 343K) |
11/2/2004 |
| Requesting a ruling concerning the federal income tax treatment, under Page 2 section 414(h)(2) of the Internal Revenue Code, of certain contributions. |
| 200504038(PDF, 79K) |
11/2/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200504037(PDF, 238K) |
11/4/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200504036(PDF, 136K) |
11/4/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(B) of the Internal Revenue Code. |
| 200504035(PDF, 24K) |
11/2/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(12). |
| 200504034(PDF, 42K) |
11/1/2004 |
| Issue: Whether Taxpayer�s retail sales of the X vehicles and Y truck semitrailer bodies described below are subject to the excise tax imposed by � 4051(a)(1) of the Internal Revenue Code on truck semitrailer bodies and chassis. |
| 200504033(PDF, 37K) |
12/14/2004 |
| Issue: Whether Forms 900, Tax Collection Waiver, received by facsimile transmission (fax)1 are legally sufficient and may Brookhaven Automated Collection System (ACS) begin accepting Forms 900 by fax. |
| 200504032(PDF, 20K) |
12/10/2004 |
| Issue: Whether there is a reasonable cause exception to the imposition of the frivolous return penalty under section 6702. |
| 200504031(PDF, 63K) |
1/26/2004 |
| Requesting a ruling concerning U.S. charities ( as defined under section 501(c)(3) ) engaging in international grant making and activities. |
| 200504030(PDF, 21K) |
10/15/2004 |
| Chief Counsel Advice concerning a taxpayer primarily engaged in the business of selling life insurance and annuity products. The taxpayer is taxable as a life insurance company under Part I of subchapter L of the Code and files its Form 1120-L (U.S. Life Insurance Company Income Tax Return) on a calendar year basis. The taxpayer recognized the deferred and uncollected premium as reported in its state's statutory annual statement and included in its reserves the obligations associated with the deferred and uncollected premiums for federal income tax purposes. |
| 200504029(PDF, 45K) |
12/8/2004 |
| Issues: (1) Whether a nonresident alien or a foreign corporation may make an election under � � 871(d) or 882(d) of the Internal Revenue Code for a taxable year in which the taxpayer derives no income from U.S. real property other than gain from the sale of the USRPI? (2) Whether a nonresident alien or foreign corporation is entitled to claim deductions for real estate tax, interest on a real estate mortgage, and other carrying charges paid during the taxable year when a USRPI is sold under FIRPTA? (3) Should the Service use deficiency procedures or math error summary procedures to deny any deductions? |
| 200504028(PDF, 65K) |
6/3/2004 |
| Request for advice on �6702 and its application to returns claiming a foreign income exclusion. |
| 200504027(PDF, 47K) |
12/21/2004 |
| Issue: What is the proper federal income tax treatment of the New York City real property tax rebate? |
| 200504026(PDF, 22K) |
10/8/2004 |
| Requesting a ruling that the surrender of a green card (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. |
| 200504025(PDF, 22K) |
10/8/2004 |
| Requesting a ruling that the surrender of a green card (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. |
| 200504024(PDF, 48K) |
10/5/2004 |
| Requesting an extension of time under � 2642(g) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations to make an allocation of the Generation-Skipping Transfer (GST) exemption to two trusts. |
| 200504023(PDF, 25K) |
10/7/2004 |
| Requesting a ruling under section 877(c) of the Internal Revenue Code of 1986 ("Code") that 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. |
| 200504022(PDF, 23K) |
10/7/2004 |
| Requesting a ruling that the surrender of a green card (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. |
| 200504021(PDF, 20K) |
10/8/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200504020(PDF, 20K) |
10/8/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200504019(PDF, 33K) |
10/15/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election. Also an extension to file a "� 338(h)(10) election" under �� 338(g) and 338(h)(10) of the Internal Revenue Code and � 1.338(h)(10)-1(d) of the Income Tax Regulations. |
| 200504018(PDF, 23K) |
10/19/2004 |
| Requesting a ruling to 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 disregarded entity for federal tax purposes. |
| 200504017(PDF, 23K) |
10/19/2004 |
| Requesting a ruling to 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 disregarded entity for federal tax purposes. |
| 200504016(PDF, 23K) |
10/19/2004 |
| Requesting a ruling to 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 disregarded entity for federal tax purposes. |
| 200504015(PDF, 23K) |
10/19/2004 |
| Requesting a ruling to 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 disregarded entity for federal tax purposes. |
| 200504014(PDF, 23K) |
10/19/2004 |
| Requesting a ruling to 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 disregarded entity for federal tax purposes. |
| 200504013(PDF, 23K) |
10/19/2004 |
| Requesting a ruling to 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 disregarded entity for federal tax purposes. |
| 200504012(PDF, 26K) |
10/14/2004 |
| Requesting a ruling to exclude gain from the sale of a townhouse under section 121(c) of the Internal Revenue Code. |
| 200504011(PDF, 26K) |
10/14/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election to be treated as an association for federal tax purposes and relief under � 1362(b)(5) of the Internal Revenue Code to file a subchapter S election. |
| 200504010(PDF, 33K) |
10/6/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Parent and Subsidiaries to file an election under � 1.1502-21(b)(3)(ii)(B) of the Income Tax Regulations to relinquish, with respect to all consolidated net operating losses attributable to Parent and Subsidiaries, the portion of the carryback period for which Parent and Subsidiaries were members of another group. |
| 200504009(PDF, 28K) |
10/14/2004 |
| Requesting a ruling to determine federal employment tax status with respect to services provided to a unit of a federal agency. |
| 200504008(PDF, 28K) |
10/8/2004 |
| Requesting a ruling that the income an agency receives from its operations is excludable from gross income under section 115 of the Internal Revenue Code. |
| 200504007(PDF, 31K) |
10/1/2004 |
| Requesting consent to revoke a previous election under section 4982(e)(4)(A) of the Internal Revenue Code. Additionally, that the calculation of required distribution of capital gain net income under section 4982(b)(1) and (e)(2) and foreign currency gains and losses under section 4982(e)(5) be determined on the basis of capital gains and losses and foreign currency gains and losses. |
| 200504006(PDF, 28K) |
10/12/2004 |
| Requesting a ruling under section 162(m) of the Internal Revenue Code. Specifically, a ruling that the compensation payable upon the exercise of certain options will constitute qualified performance-based compensation for purposes of section 162(m). |
| 200504005(PDF, 20K) |
10/12/2004 |
| Requesting a ruling under � 301.9100-3(a) of the Procedure and Administration Regulations to be granted an extension of time in which to make an election under � 754 of the Internal Revenue Code. |
| 200504004(PDF, 33K) |
10/5/2004 |
| 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. |
| 200504003(PDF, 22K) |
10/8/2004 |
| Requesting a ruling that loss of U.S. lawful permanent residence (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. |
| 200504002(PDF, 24K) |
10/7/2004 |
| Requesting a ruling that loss of U.S. lawful permanent residence (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. |
| 200504001(PDF, 38K) |
10/12/2004 |
| Issue: Whether damages from a class action lawsuit against Insurer are includible in the Taxpayer�s income. |
| 200503036(PDF, 279K) |
10/25/2004 |
| Requesting a ruling as to whether a "make-up" distribution from an individual retirement arrangement will not result in a modification to a series of substantially equal periodic payments currently being received and, therefore, not subject to the additional 10 percent tax imposed on premature distributions under section 72(t) of the Internal Revenue Code. |
| 200503035(PDF, 243K) |
10/25/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in setion 402(c)(3)(A) of the Internal Revenue Code. |
| 200503034(PDF, 165K) |
10/28/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in setion 408(d)(3) of the Internal Revenue Code. |
| 200503033(PDF, 263K) |
10/25/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200503032(PDF, 241K) |
10/25/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c)(3)(A) of the Internal Revenue Code. |
| 200503031(PDF, 79K) |
7/27/2004 |
| Requesting for review of a draft service center advice concerning foreign earned income and Form 2555. |
| 200503030(PDF, 18K) |
10/25/2004 |
| Requesting advance approval of grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200503029(PDF, 17K) |
10/28/2004 |
| Requesting a ruling concerning the status, for federal tax purposes, of a qualified subsidiary of a title-holding corporation under section 501(c)(25) of the Internal Revenue Code. |
| 200503028(PDF, 15K) |
10/29/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200503027(PDF, 22K) |
10/28/2004 |
| Requesting the following rulings: (1) The proposed transactions will not adversely affect the tax-exempt status of the VEBA trust under section 509(c)(9) of the Code. (2) Distributions by Newco to its members who are also Participating Employers of the Trust will not result in the imposition of excise tax on the Participating Employers pursuant to section 4976 of the Code. |
| 200503026(PDF, 29K) |
10/26/2004 |
| Issues: (1) Are stock issuance costs netted against stock proceeds, or do stock issuance costs create a separate intangible asset? (2) If stock issuance costs are not netted against stock proceeds, may a target corporation deduct, under �165 of the Internal Revenue Code, the target�s previously incurred stock issuance costs when the target is acquired in a statutory merger that qualifies as a tax-free reorganization under � 368(a)(1)(A)? |
| 200503025(PDF, 38K) |
10/6/2004 |
| 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 Husband�s and Wife�s respective generation-skipping transfer (GST) tax exemptions. |
| 200503024(PDF, 50K) |
10/5/2004 |
| Requesting a ruling that Wife�s disclaimer of her survivorship interest in Wife and Husband�s joint brokerage account will be a qualified disclaimer for purposes of � 2518 of the Internal Revenue Code. |
| 200503023(PDF, 22K) |
9/28/2004 |
| Requesting a ruling that Corporation be granted permission to revoke its election under � 41(c)(4) of the Internal Revenue Code. |
| 200503022(PDF, 22K) |
9/28/2004 |
| Requesting permission to revoke an election under � 41(c)(4) of the Internal Revenue Code. |
| 200503021(PDF, 40K) |
10/6/2004 |
| Requesting a waiver under sections 101(f)(3)(H) and 7702(f)(8) of the Internal Revenue Code for life insurance contracts that inadvertently failed to meet the requirements of section 101(f) or section 7702, as applicable. |
| 200503020(PDF, 23K) |
10/1/2004 |
| Requesting inadvertent termination relief under � 1362(f) of the Internal Revenue Code. |
| 200503019(PDF, 22K) |
10/6/2004 |
| Requesting an extension of time to elect to be treated as an association taxable as a corporation under � 301.7701-3(c) of the Procedure and Administration Regulations. |
| 200503018(PDF, 24K) |
12/6/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as an association taxable as a corporation for federal tax purposes. |
| 200503017(PDF, 35K) |
10/5/2004 |
| Requesting rulings on the federal income tax consequences of the proposed transactions as follows. (i) Distributing will transfer Business G to Controlled, together with cash, assets, and liabilities associated with that business, in exchange for w shares of Controlled common stock, constituting all of the outstanding stock of Controlled; and (ii) Distributing immediately thereafter will make a pro rata distribution of all of the outstanding stock of Controlled to its shareholders. |
| 200503016(PDF, 25K) |
9/29/2004 |
| Requesting a ruling that the rental income received by a company from property is not passive investment income within the meaning of � 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200503015(PDF, 32K) |
10/4/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election. Requesting an extension to file a �� 338(h)(10) election� under �� 338(g) and 338(h)(10) of the Internal Revenue Code and � 1.338(h)(10)-1(d)(2) of the Income Tax Regulations. (All citations in this letter to regulations under � 338 are to regulations.) |
| 200503014(PDF, 74K) |
9/30/2004 |
| Requesting rulings concerning the federal income tax consequences of a proposed transaction described within. |
| 200503013(PDF, 27K) |
9/30/2004 |
| Request for rulings concerning foreign company stock ownership in a certain U.S. corporation involved in a certain business that intends to join with a subsidiary in the filing of a consolidated return. |
| 200503012(PDF, 33K) |
9/27/2004 |
| Requesting rulings concerning the federal income tax consequences of a proposed transaction described within. |
| 200503011(PDF, 44K) |
9/27/2004 |
| Requesting a revised schedule of ruling amounts in accordance with section 1.468A-3(i)(2) of the Income Tax Regulations. Information was submitted pursuant to section 1.468A-3(h)(2). |
| 200503010(PDF, 36K) |
9/30/2004 |
| Requesting a ruling regarding the applicability of � 2702 of the Internal Revenue Code. |
| 200503009(PDF, 36K) |
9/30/2004 |
| Requesting a ruling regarding the applicability of � 2702 of the Internal Revenue Code. |
| 200503008(PDF, 36K) |
9/30/2004 |
| Requesting a ruling regarding the applicability of � 2702 of the Internal Revenue Code. |
| 200503007(PDF, 36K) |
9/30/2004 |
| Requesting a ruling regarding the applicability of � 2702 of the Internal Revenue Code. |
| 200503006(PDF, 36K) |
9/30/2004 |
| Requesting a ruling regarding the applicability of � 2702 of the Internal Revenue Code. |
| 200503005(PDF, 46K) |
9/28/2004 |
| Requesting a revised schedule of ruling amounts pursuant to section 1.468A-3(i)(2) of the Income Tax Regulations. The request for a revised schedule of ruling amounts is the result of a commission increasing the decommissioning costs to be included in cost of service for ratemaking purposes. Information was submitted pursuant to section 1.468A-3(h)(2). |
| 200503004(PDF, 34K) |
9/29/2004 |
| Requesting rulings on behalf of Taxpayer that: (1) a potential loan to Foundation will be classified as "property held for investment" under � 163 of the Internal Revenue Code; (2) any interest earned on the loan will be "investment income" under � 163; and (3) any interest paid on a line of credit used to make the loan will be "investment interest" under � 163. |
| 200503003(PDF, 35K) |
10/6/2004 |
| Requesting the following rulings: (1) The hydrocarbon recovered from the Y formation through open pit mining is oil from tar sands, and not crude oil, for purposes of � 613A and � 291(b). (2) The hydrocarbon recovered from the X lease, through use of Process is oil from tar sands, and not crude oil, for purposes of � 613A and � 291(b). (3) Refining tar sand oil is not the refining of crude oil under � 613A(d)(4) (4) The volume of tar sand oil processed in an upgrader or refinery is disregarded under the 50,000 barrel per day crude oil exclusion under � 613A(d)(4). (5) The refining of tar sand oil by Corporation�s proposed joint venture is not relevant to the determination of whether Corporation is an integrated oil company under � 291(b). |
| 200503002(PDF, 43K) |
9/28/2004 |
| Requesting a ruling regarding the generation-skipping transfer (GST) tax consequences of a proposed modification of a trust. |
| 200503001(PDF, 30K) |
10/5/2004 |
| Requesting advice concerning the military power of attorney. |
| 200502054(PDF, 287K) |
10/19/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200502053(PDF, 198K) |
10/19/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200502052(PDF, 142K) |
10/15/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 402(c) of the Internal Revenue Code. |
| 200502051(PDF, 245K) |
10/20/2004 |
| Requesting relief under sections 301.9100-1 and 901.9100-3 of the Procedure and Administration Regulations. |
| 200502050(PDF, 219K) |
10/19/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200502049(PDF, 209K) |
10/18/2004 |
| Requesting a waiver of the 60-day rollover requirement contained in section 408(d)(3) of the Internal Revenue Code. |
| 200502048(PDF, 116K) |
10/22/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200502047(PDF, 209K) |
10/18/2004 |
| Requesting a ruling with respect to the federal income tax treatment of certain contributions under section 414(h)(2) of the Internal Revenue Code. |
| 200502046(PDF, 45K) |
10/18/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200502045(PDF, 19K) |
10/22/2004 |
| Requesting advance approval of your grant procedures under section 4945(g) of the Internal Revenue Code. |
| 200502044(PDF, 22K) |
6/28/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(3). |
| 200502043(PDF, 23K) |
10/19/2004 |
| Requesting the following rulings: (1) The proposed transactions will not adversely affect the tax-exempt status of the VEBA trust under section 501(c)(9) of the Code. (2) The proposed transaction will not result in the imposition of tax on the employer members under section 4976 of the Code. (3) The distributions from member employers to employees will constitute �rebates� as contemplated in section 1.501(c)(9)-4(c) of the regulations. (4) The distributions to employees by member employers will not result in the VEBA trust incurring unrelated business taxable income under section 511 of the Code. |
| 200502042(PDF, 66K) |
7/27/2004 |
| Requesting advice concerning 6702 farming income credit. |
| 200502041(PDF, 109K) |
10/26/2004 |
| Issues: (1) Whether any portion of a lump-sum settlement payment made to settle claims arising under the False Claims Act, 31 U.S.C. �� 3729-33 (2000), constitutes a nondeductible fine or penalty within the meaning of � 162(f) of the Internal Revenue Code. (2) Whether any portion of a lump-sum settlement payment made to settle claims arising under the False Claims Act constitutes compensatory damages attributable to costs incurred by the government while investigating and settling the alleged false claims (e.g., investigation costs, amounts paid to relators, and pre-settlement interest). |
| 200502040(PDF, 96K) |
1/14/2005 |
| Issues: (1) Are amounts includible in the gross income of an employee as a result of a group universal life insurance program offered to the employees of the Taxpayer? (2) Are amounts includible in the gross income of an employee as a result of a dependent group life insurance program offered to employees of the Taxpayer? |
| 200502039(PDF, 90K) |
1/14/2005 |
| Issue: Are an acquired corporation�s (�T�) pre-acquisition transaction costs (investment banking, legal and accounting fees) that were previously capitalized under section 263 of the Internal Revenue Code by T deductible under section 165 as a result of T�s subsequent state law dissolution where, just prior to such dissolution, T transfers all of its property to its parent corporation in a transaction to which sections 332 and 337 apply, and T�s business and assets continue to be held and operated by the parent corporation? |
| 200502038(PDF, 22K) |
10/5/2004 |
| Requesting a ruling that renunciation of his U.S. 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. |
| 200502037(PDF, 66K) |
9/30/2004 |
| Requesting rulings concerning the proposed division of a trust into two separate trusts. |
| 200502036(PDF, 42K) |
9/27/2004 |
| Requesting a ruling on the generation-skipping transfer (GST) tax consequences of severing a trust into two separate trusts pursuant to � 2642(a)(3) of the Internal Revenue Code. |
| 200502035(PDF, 36K) |
9/30/2004 |
| Requesting a ruling regarding the applicability of � 2702 of the Internal Revenue Code. |
| 200502034(PDF, 30K) |
9/28/2004 |
| Requesting an extension of time under Treas. Reg. � 301.9100-3 to file the election agreement described in � 1.1503-2(g)(2)(i), and to file the annual certification described in � 1.1503- 2(g)(2)(vi)(B). |
| 200502033(PDF, 25K) |
9/28/2004 |
| Requests an extension of time under Treas. Reg. � 301.9100-3 to file the election agreement described in � 1.1503-2(g)(2)(i), and to file the annual certification described in � 1.1503- 2(g)(2)(vi)(B). |
| 200502032(PDF, 68K) |
9/30/2004 |
| Requesting rulings on the income and generation-skipping transfer (GST) tax consequences of a division and modification of a trust. |
| 200502031(PDF, 66K) |
9/30/2004 |
| Requesting rulings on the income and generation-skipping transfer (GST) tax consequences of a division and modification of a trust. |
| 200502030(PDF, 19K) |
9/30/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200502029(PDF, 23K) |
9/9/2004 |
| Requesting permission to change an accounting period for federal income tax purposes under Form 1128. Also requesting that the Form 1128 be considered timely filed under the authority contained in � 301.9100-3 of the Procedure and Administration Regulations. |
| 200502028(PDF, 22K) |
9/28/2004 |
| Requesting a ruling to be granted permission to revoke an election under � 41(c)(4) of the Internal Revenue Code. |
| 200502027(PDF, 20K) |
10/4/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200502026(PDF, 19K) |
10/4/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200502025(PDF, 17K) |
9/14/2004 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. |
| 200502024(PDF, 30K) |
9/27/2004 |
| Requesting inadvertent termination relief under � 1362(f) of the Internal Revenue Code. |
| 200502023(PDF, 64K) |
9/23/2004 |
| Requesting rulings under � 29 of the Internal Revenue Code. |
| 200502022(PDF, 65K) |
9/23/2004 |
| Requesting rulings under � 29 of the Internal Revenue Code. |
| 200502021(PDF, 27K) |
8/26/2004 |
| Requesting a ruling to be given an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to elect under � 301.7701-3(c) to be treated as an association taxable as a corporation for federal tax purposes and be granted relief under � 1362(f) of the Internal Revenue Code. |
| 200502020(PDF, 20K) |
9/20/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200502019(PDF, 67K) |
9/30/2004 |
| Requesting a ruling that, for purposes of � 42(d)(2)(B)(ii) of the Internal Revenue Code, there is a period of 10 years between the date on which a certain building is expected to be acquired and the date the building was last placed in service. |
| 200502018(PDF, 57K) |
9/22/2004 |
| Requesting a ruling concerning the estate tax and generation-skipping transfer (GST) tax consequences of a proposed modification of a trust and the appointment of a successor trustee. |
| 200502017(PDF, 60K) |
9/22/2004 |
| Requesting a ruling concerning the estate tax and generation-skipping transfer (GST) tax consequences of a proposed modification of a trust and the appointment of a successor trustee. |
| 200502016(PDF, 41K) |
9/29/2004 |
| Requesting rulings as to the federal income tax consequences of the proposed transaction between Businesses A and B as follows. (i) Distributing will contribute the Business B assets to Controlled in exchange for all of the Controlled stock and the assumption of liabilities associated with Business B (the �Contribution�); (ii) Distributing will distribute all of the stock of Controlled pro rata to its shareholders (the �Distribution�). Distributing shareholders will receive cash in lieu of fractional shares; (iii) Distributing and Controlled will enter into a Separation and Distribution Agreement, a Tax Sharing Agreement, a Transition Services Agreement, and a Manufacturing Agreement (collectively, the �Agreements�) to define their relationships after the Transaction. |
| 200502015(PDF, 22K) |
9/27/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200502014(PDF, 53K) |
9/17/2004 |
| Requesting rulings under �� 671 and 2501 of the Internal Revenue Code. |
| 200502013(PDF, 26K) |
10/1/2004 |
| Requesting a ruling under � 216 of the Internal Revenue Code. |
| 200502012(PDF, 69K) |
9/28/2004 |
| Requesting a ruling that the acquisition of various interests in land and related arrangements will not give rise to private business use within the meaning of � 141 of the Internal Revenue Code. Also that the related arrangements are uses related and not disproportionate to the government use of the proceeds. |
| 200502011(PDF, 25K) |
9/28/2004 |
| Requesting an extension of time under Treas. Reg. � 301.9100-3 to file the election agreement described in � 1.1503-2(g)(2)(i), and the annual certification described in � 1.1503-2(g)(2)(vi)(B). |
| 200502010(PDF, 35K) |
9/28/2004 |
| Requesting rulings under �� 355 and 368 of the Internal Revenue Code with respect to a proposed transaction. |
| 200502009(PDF, 36K) |
9/30/2004 |
| Requesting a ruling regarding the applicability of � 2702 of the Internal Revenue Code. |
| 200502008(PDF, 36K) |
9/30/2004 |
| Requesting a ruling regarding the applicability of � 2702 of the Internal Revenue Code. |
| 200502007(PDF, 58K) |
9/29/2004 |
| Requesting a revised schedule of ruling amounts relating to a qualified nuclear decommissioning fund. |
| 200502005(PDF, 25K) |
10/1/2004 |
| Requesting a ruling under section 877(c) of the Internal Revenue Code of 1986 ("Code") that 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. |
| 200502005(PDF, 30K) |
9/30/2004 |
| Requesting a ruling, under section 301.9100-3 of the Procedure and Administration Regulations and under section 1362(b)(5) of the Internal Revenue Code, to be granted an extension of time to elect to be treated as a corporation for federal tax purposes, to elect to be treated as an S corporation, and to elect to treat a wholly owned subsidiary as a Qualified subchapter S subsidiary (QSub). |
| 200502004(PDF, 43K) |
9/30/2004 |
| Requesting a ruling that the original use of an aircraft commenced with purposes of the 50-percent additional first year depreciation deduction provided by section 168(k)(4) of the Internal Revenue Code. |
| 200502003(PDF, 22K) |
9/28/2004 |
| Requesting an extension of time under Treas. Reg. � 301.9100-3 to file the election statement described in � 1.954-2(g)(3). |
| 200502002(PDF, 24K) |
9/30/2004 |
| Requesting a ruling that stipends, vouchers, or reimbursements for transportation or respite care are not includible in the income of the beneficiaries of these services and that the Taxpayer is not required by � 6041 of the Internal Revenue Code to file information returns as a result of providing the payments to the beneficiaries. |
| 200502001(PDF, 27K) |
9/23/2004 |
| Requesting an extension of time under Treas. Reg. � 301.9100-3 to file the annual certification described in �1.1503-2(g)(2)(vi). |
| 200501025(PDF, 158K) |
6/14/2004 |
| Requesting rulings on certain federal income tax consequences of the series of proposed transactions described within. |
| 200501024(PDF, 78K) |
10/14/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200501023(PDF, 129K) |
10/14/2004 |
| Requesting a waiver of the minimum funding standard. |
| 200501022(PDF, 34K) |
10/13/2004 |
| Requesting whether participation in a securities lending program will involve an act of self-dealing as defined in section 4941(d) of the Internal Revenue Code of 1986. |
| 200501021(PDF, 34K) |
10/13/2004 |
| Requesting whether participation in a securities lending program will involve an act of self-dealing as defined in section 4941(d) of the Internal Revenue Code of 1986. |
| 200501020(PDF, 15K) |
10/12/2004 |
| Requesting exemption from federal income tax under section 501(a) of the Internal Revenue Code as an organization described in section 501(c)(4). |
| 200501019(PDF, 25K) |
10/15/2004 |
| Requesting rulings under sections 507, 4940, 4941, 4942, 4944 and 4945 of the Internal Revenue Code concerning a transfer under section 507(b)(2) of one-half of X's assets. |
| 200501018(PDF, 25K) |
10/15/2004 |
| Requesting rulings under sections 507, 4940, 4941, 4942, 4944 and 4945 of the Internal Revenue Code concerning a transfer under section 507(b)(2) of one-half of X's assets. |
| 200501017(PDF, 14K) |
10/15/2004 |
| Requesting rulings regarding the tax consequences associated with providing liability insurance to a for profit entity which is a subsidiary of another entity. |
| 200501016(PDF, 46K) |
9/21/2004 |
| Issues: (1) Do the reporting requirements of section 6050I of the Internal Revenue Code (Code) apply when a single customer purchases multiple items of personal property at the same time and pays for the purchase via a series of cash payments totaling in excess of $10,000? (2) Are X�s employees deemed separate recipients for purposes of section 6050I of the Code? (3) Is X subject to either the Failure to File Correct Information Returns penalty under section 6721(a) or the Intentional Disregard penalty under section 6721(e) of the Code? |
| 200501015(PDF, 16K) |
8/31/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200501014(PDF, 36K) |
9/24/2004 |
| Requesting relief (1) for X to make a late S corporation election under � 1362(b)(5) of the Internal CC:PSI:B1-PLR-171510-03 2 Revenue Code; (2) for X to be treated as continuing to be an S corporation under � 1362(f); and (3) for X to make a late Qualified Subchapter S Subsidiary Corporation (QSub) election under � 301.9100 of the Procedure and Administration Regulations for Y. |
| 200501013(PDF, 27K) |
9/29/2004 |
| Requesting a ruling under � 1362(f) of the Internal Revenue Code. |
| 200501012(PDF, 25K) |
9/27/2004 |
| Requesting a ruling under � 301.9100-3(a) of the Procedure and Administration Regulations to be granted an extension of time to make an election to be classified as a partnership. |
| 200501011(PDF, 27K) |
9/24/2004 |
| Requesting relief to be treated as continuing to be an S corporation under � 1362(f). |
| 200501010(PDF, 18K) |
9/20/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200501009(PDF, 65K) |
9/23/2004 |
| Requesting rulings under � 29 of the Internal Revenue Code. |
| 200501008(PDF, 23K) |
9/14/2004 |
| Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as a disregarded entity under � 301.7701-3(c). |
| 200501007(PDF, 20K) |
9/20/2004 |
| Requesting a ruling under � 1362(b)(5) of the Internal Revenue Code. |
| 200501006(PDF, 57K) |
9/22/2004 |
| Request concerning the estate tax and generation-skipping transfer (GST) tax consequences of a proposed modification of a trust and the appointment of a successor trustee. |
| 200501005(PDF, 23K) |
9/29/2004 |
| Requesting an extension of time under Treas. Reg. � 301.9100-3 to file the statements described in � 1.1503-2A and � 1.1503-2. |
| 200501004(PDF, 76K) |
9/2/2004 |
| Issues: (1) Use by Utility 1 and Utility 2 of the Generator Components pursuant to the Project will not be private business use of the proceeds of the Bonds. (2) The Service Provider�s use of the Generator Components pursuant to the Contracts will not be private business use of the proceeds of the Bonds. |
| 200501003(PDF, 76K) |
9/2/2004 |
| Issues: (1) Use by Utility 1 and Utility 3 of the Generator Components pursuant to the Project will not be private business use of the proceeds of the Bonds. (2) The Service Provider�s use of the Generator Components pursuant to the Contracts will not be private business use of the proceeds of the Bonds. |
| 200501002(PDF, 24K) |
9/14/2004 |
| Requesting an extension under � 301.9100-3 of the Procedure and Administration Regulations to elect to be treated as an association taxable as a corporation for federal tax purposes. |
| 200501001(PDF, 42K) |
9/21/2004 |
| Issues: (1) How many members does LLC have for federal tax purposes? (2) Does the fact that Son originally indicated that Father was a member affect the determination of whether LLC is a single- or multi-member entity? (3) How is it determined how many members an LLC has for federal tax purposes? (4) If Son reported the income and expenses from the business on his Schedules C, and represents that he is the only member, should this be enough to consider the LLC a single member LLC and treat it as such back to Year 1? (5) If no income/loss from the business had been reported on any type of tax return, would this make a difference in this particular case? In the alternative, if one member reports all the income from the business, does this preclude anyone else from being a member of the LLC? (6) As active involvement by all the members of an LLC is not a requirement for the LLC to be treated as a multi-member LLC, and as there is no formal form filed either with the state or federal government that indicates who the members of the LLC are, how does the Service determine if there are actually multiple members other than relying on the interviewed taxpayer's word? |
| 20050062(PDF, 142K) |
3/21/2005 |
| Requesting general information concerning the taxation and withholding requirements for employers who hire employees who are H-3 visa holders. |
| 20050061(PDF, 78K) |
1/8/2004 |
| Requesting late S corporation election relief. |
| 20050060(PDF, 78K) |
11/20/2003 |
| Requesting recognition of an election to be an S corporation. |
| 20050059(PDF, 176K) |
10/21/2004 |
| Requesting information regarding certain qualified parking plans with reference to section 132 of the Internal Revenue Code. |
| 20050058(PDF, 63K) |
11/18/2004 |
| Requesting recognition of an election to be an S corporation. |
| 20050057(PDF, 69K) |
3/29/2004 |
| Requesting advice regarding Form 1099-R. |
| 20050056(PDF, 34K) |
3/15/2004 |
| Requesting information regarding a claim for the child tax credit. |
| 20050055(PDF, 52K) |
3/30/2004 |
| Requesting information regarding the capital gains tax with references to sections 121(a), 121(d)(3)(B) and 1.121-4(b)(2). |
| 20050054(PDF, 41K) |
7/27/2004 |
| Requesting information regarding non-profit hospitals described in section 501(c)(3) of the Internal Revenue Code. |
| 20050053(PDF, 78K) |
3/24/2005 |
| Requesting information regarding non-profit hospitals described in section 501(c)(3) of the Internal Revenue Code. |
| 20050052(PDF, 137K) |
1/4/2005 |
| Requesting information as to whether a tax-exempt organization would be deemed to have satisfied the public inspection and distribution requirements as set forth in section 301.6104(d)-1 of the Procedure and Administration Regulations. |
| 20050051(PDF, 205K) |
1/26/2004 |
| Requesting information regarding a hospital described in section 501(c)(3) of the Internal Revenue Code involved in a joint venture operating as a limited liability company. |
| 20050050(PDF, 16K) |
2/14/2005 |
| Requesting whether (1) a stipend payment under Article 18 section 23-18-201(1) issued to eligible students is subject to federal income taxation and (2) whether the answer to issue (1) would be different under pending legislation that would classify the stipend payments as refunds of taxes for state budgeting purposes. |
| 20050049(PDF, 13K) |
2/3/2005 |
| Requesting a private letter ruling concerning the federal income tax consequences of the sale of a remainder interest in a single family residential property. |
| 20050048(PDF, 11K) |
3/3/2005 |
| Requesting recognition of the Taxpayer�s S election. |
| 20050047(PDF, 9K) |
3/3/2005 |
| Requesting advice regarding � 301.7701-3 of the Procedure and Administration Regulations. |
| 20050046(PDF, 15K) |
1/12/2005 |
| Requesting certain information regarding Article 18 (Teaching and Research), of the Convention Between the United States of America and Trinidad and Tobago for the Avoidance of Double Taxation, the Prevention of Fiscal Evasion with Respect to Taxes on Income, and the Encouragement of International Trade and Development. |
| 20050045(PDF, 62K) |
5/19/2004 |
| Requesting rulings concerning the tax treatment of various expense reimbursements under section 62(c) and (a)(2)(A) of the Internal Revenue Code. |
| 20050044(PDF, 9K) |
1/24/2005 |
| Requesting recognition of an election to be an S corporation. |
| 20050043(PDF, 13K) |
2/7/2005 |
| Requesting a late S corporation election. |
| 20050042(PDF, 13K) |
2/25/2005 |
| Requesting an S corporation election. |
| 20050041(PDF, 13K) |
2/8/2005 |
| Requesting a late S corporation election. |
| 20050040(PDF, 18K) |
3/2/2005 |
| Requesting information on sections 6041 and 6041A of the Internal Revenue Code. |
| 20050039(PDF, 19K) |
2/7/2005 |
| Requesting views on a draft opinion regarding the applicability of the generationskipping transfer (GST) tax to certain group life insurance program benefits provided by the Department of Veterans Affairs. |
| 20050038(PDF, 16K) |
2/15/2005 |
| Requesting a waiver that will allow the City of Detroit Planning and Development Department to allocate commercial revitalization expenditure amounts to Taxpayer for a commercial building placed in service in the Detroit renewal community. |
| 20050037(PDF, 9K) |
1/10/2005 |
| Requesting recognition of Taxpayer�s election to be an S corporation. |
| 20050036(PDF, 11K) |
1/12/2005 |
| Requesting recognition of Taxpayer�s election to be an S corporation. |
| 20050035(PDF, 9K) |
1/10/2005 |
| Requesting recognition of Taxpayer�s election to be an S corporation. |
| 20050034(PDF, 8K) |
3/2/2005 |
| Requesting relief for the failure to file a timely Form 2553. |
| 20050033(PDF, 10K) |
1/10/2005 |
| Requesting recognition of an election to be an S corporation. |
| 20050032(PDF, 17K) |
1/5/2005 |
| Requesting clarification of the definition of the word �individual� in the context of Title 26, Chapter 2, of the Internal Revenue Code (the �Code�) imposing tax on self-employment income. Definition of the word �individual� as used in sections 1401-1403 of the Code. Also a note regarding section 6017 of the Code and its use of the word �individual�, as well as a Black�s Law Dictionary (Seventh Edition) definition of the word "individual". |
| 20050031(PDF, 14K) |
12/7/2004 |
| Requesting information concerning the law applicable to an incentive stock option (ISO) with reference to section 424 of the Internal Revenue Code. |
| 20050030(PDF, 8K) |
1/26/2005 |
| Requesting relief for the failure to file a timely Form 2253. |
| 20050029(PDF, 11K) |
1/4/2005 |
| Requesting recognition of an election to be an S corporation. |
| 20050028(PDF, 7K) |
1/10/2005 |
| Requesting the retroactive revocation of Taxpayer�s S corporation election. |
| 20050027(PDF, 7K) |
1/4/2005 |
| Requesting information regarding relief for a late S corporation election. |
| 20050026(PDF, 7K) |
5/13/2004 |
| Requesting an S corporation election. |
| 20050025(PDF, 14K) |
3/2/2005 |
| Requesting recognition of an election to be an entity taxable as an association with reference to section 301.7701 of the Procedure and Administration Regulations. |
| 20050024(PDF, 17K) |
2/18/2005 |
| Requesting general information regarding the applicability of Social Security coverage to firefighters. Tthe firefighters participate in their own mandatory firefighter pension system. |
| 20050023(PDF, 11K) |
2/25/2005 |
| Requesting recognition of an election to be an S corporation. |
| 20050022(PDF, 76K) |
3/17/2004 |
| Requesting automatic relief in order to establish the effective tax year for an S corporation election. |
| 20050021(PDF, 11K) |
2/23/2005 |
| Requesting information regarding the June 2004 memorandum in reference to the Flood Mitigation Assistance Program and other related programs. |
| 20050020(PDF, 11K) |
1/24/2005 |
| Requesting recognition of an election to be an S corporation. |
| 20050019(PDF, 17K) |
2/23/2005 |
| Requesting information regarding the June 2004 memorandum in reference to the Flood Mitigation Assistance Program, the Pre-Disaster Mitigation Program and the Hazard Mitigation Grant Program. |
| 20050018(PDF, 28K) |
2/23/2005 |
| Requesting a determination of eligibility to exclude housing allowance from gross income in light of the perceived similarities between the functions and qualifications of deacons as described in a 1998 letter ruling. |
| 20050017(PDF, 14K) |
1/11/2005 |
| Requesting information with concern that the recipient of a grant used to fund improvements to property under Federal Emergency Management Agency (FEMA) mitigation programs must include the grant in gross income. |
| 20050016(PDF, 6K) |
3/7/2005 |
| Requesting information regarding the offset of bond interest income with losses incurred on sales of stock. |
| 20050015(PDF, 114K) |
6/24/2004 |
| Requesting a ruling letter on the proper tax treatment of travel expense reimbursements paid to an employee who works out of residence in one state but who regularly travels to the taxpayer's office in another state and stays in a corporate apartment provided by the taxpayer for that time. |
| 20050014(PDF, 17K) |
1/6/2005 |
| Requesting information on new legislation, enacted as part of the Jobs Creation Act, that provides a deduction for production costs of certain film or television productions (Section 181 of the Internal Revenue Code). Specifically, whether the benefits of the provision will be available to corporate investors, individual investors, or both. |
| 20050013(PDF, 14K) |
12/27/2004 |
| Requesting information regarding the inclusion of income payments received from a corporation as reimbursement for the reduced market value of homes due to chemical contamination and how these payments should be reported on federal income tax returns. |
| 20050012(PDF, 14K) |
11/15/2004 |
| Requesting clarification of the rules determining whether certain agent-drivers and commission drivers are statutory employees (section 3121(d)(3)(A) of the Internal Revenue Code (the Code)). Also requesting reconsideration of the position taken in General Counsel Memorandum (GCM) 39853 (June 20, 1991), which concludes that route ownership is not an investment in facilities that exempts a worker from statutory employee status if the investment is substantial. |
| 20050011(PDF, 10K) |
3/14/2005 |
| Requesting information about deducting the cost of drugs imported from Canada. |
| 20050010(PDF, 18K) |
10/15/2004 |
| Requesting information regarding whether a city can transfer amounts from its eligible governmental section 457(b) deferred compensation plan to a governmental defined benefit plan for the purchase of permissive service credits, without tax consequences. |
| 20050009(PDF, 16K) |
4/23/2004 |
| Requesting information regarding the use of 401(k) savings to help supplement health care costs with oppostion to the 10 percent penalty incurred when using 401(k) funds for this purpose. |
| 20050008(PDF, 10K) |
3/14/2005 |
| Requesting information regarding the deduction of the cost of drugs and needles without insurance coverage. |
| 20050007(PDF, 8K) |
3/4/2005 |
| Requesting the name of a bill that taxes up to eighty percent of a social security recipient�s annuity based on the income of both spouses and the year the bill passed (possibly section 86 of the Internal Revenue Code). |
| 20050006(PDF, 10K) |
3/2/2005 |
| Requesting information regarding the June 2004 memorandum in reference to the Flood Mitigation Assistance Program, the Pre-Disaster Mitigation Program and the Hazard Mitigation Grant Program. |
| 20050005(PDF, 10K) |
3/2/2005 |
| Requesting information regarding the June 2004 memorandum in reference to the Flood Mitigation Assistance Program, the Pre-Disaster Mitigation Program and the Hazard Mitigation Grant Program. |
| 20050004(PDF, 15K) |
2/28/2005 |
| Requesting information about the new rules for vehicle donations under Section 170(f)(12) of the Internal Revenue Code and also if sales of donated vehicles by these organizations are in direct furtherance of the organizations� charitable purposes. |
| 20050003(PDF, 17K) |
2/14/2005 |
| Requesting information regarding whether �reclassifying� a tuition voucher as a tax refund would increase an individual�s federal taxable income. |
| 20050002(PDF, 18K) |
1/27/2005 |
| Requesting a general information letter addressing six tax law principles affecting the adult fitness industry with reference to section 501(c)(3). |
| 20050001(PDF, 9K) |
12/23/2004 |
| Inquiry regarding the tax law changes affecting sections 1031 and 121 of the Internal Revenue Code. |
