Chief Counsel's Written Determinations Issued from 200100000 to 200104999

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.

200104030(PDF, 13K)	1/26/2001
Requesting for assistance, dated September 29, 2000, regarding a federal receivership established by Judge in a criminal case entitled W. Specifically, you have asked whether the receiver appointed in this case must file income tax returns for closely held corporations that owned prior to K creating the receivership.
200104029(PDF, 163K)	1/26/2001
Joining with the Third, Seventh, Eighth, Ninth, and Tenth CInternal Revenue Codeuits, the First CInternal Revenue Codeuit agreed with the Government that the three-year statutory priority period of B.C. § 507(a)(8)(A)(i) should be automatically tolled for those periods in which the debtor was in a prior bankruptcy. Young v. United States, 2000 U.S. App. LEXIS 30156 (1 st Cir. Dec. 1, 2000). Three other cInternal Revenue Codeuits (the Fifth, Sixth and Eleventh) have permitted equitable tolling on a case-by-case basis under B.C. § 105(a).
200104028(PDF, 15K)	1/26/2001
Requesting rulings under § 355 of the Internal Revenue Code (the "Code") with respect to a proposed transaction. Distributing is a State corporation that files its federal income tax return on a calendar year basis. Distributing made a Subchapter S election effective Date 1, and has been an S corporation continuously since then.
200104027(PDF, 13K)	1/26/2001
Requesting an extension of time, under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election (the "Election") under § 1.1502-75(a)(1) of the Income Tax Regulations.
200104026(PDF, 10K)	1/26/2001
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 .
200104025(PDF, 8.0K)	1/26/2001
Requested a supplemental ruling to PLR 200011017 issued on December 14, 1999 ("Prior Letter Ruling"). The Prior Letter Ruling stated that the business purpose for the spin-off was to facilitate substantial borrowing by Controlled, the proceeds of which would be used to fund specific acquisitions. Consistent with the Prior Letter Ruling, the spin-off has facilitated substantial incremental borrowing by Controlled, which had borrowed approximately $X through Date 1.
200104024(PDF, 17K)	1/26/2001
Requested rulings on behalf of Distributing regarding the federal income tax consequences of certain transactions. The taxpayer has made the following representations with respect to the proposed Spin-offs: (a) No part of the consideration to be distributed by Distributing will be received by a shareholder as a creditor, employee, or in any capacity other than that of a Distributing shareholder.
200104023(PDF, 26K)	1/26/2001
Requesting rulings under §§ 2041, 2514, and 2601 of the Internal Revenue Code concerning a proposed division of Trust and the modification of the fiduciary succession provisions contained in Trust.
200104022(PDF, 12K)	1/26/2001
Requesting rulings on the application of � 162(m)(4) of the Internal Revenue Code, and the regulations thereunder, to the assumption of Taxpayer's incentive compensation plan (Plan) by Parent in the transaction described below.
200104021(PDF, 7.1K)	1/26/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200104020(PDF, 24K)	1/26/2001
Requesting rulings under � 83, 404(a)(5), 451, 3402, 3101, 3111, and 1032 of the Internal Revenue Code. Specifically, the letter requests rulings, under the facts outlined below, that the grant of an option, with a premium price reimbursement, is a nonstatutory stock option with no readily ascertainable fair market value under � 83; that a participant will not have compensation income when an option vests; that a participant recognizes compensation income when an option is exercised; that the amount of compensation recognized will be subject to income tax withholding under � 3402 and taxes under � 3101 and 311.
200104019(PDF, 23K)	1/26/2001
Issue: Whether interest received in year X by domestic subsidiaries of USparent on loans to affiliated controlled foreign corporations ("CFCs") is foreign oil and gas extraction income ("FOGEI").
200104018(PDF, 6.7K)	1/26/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year (1) A, the secretary of X, represents that X was intended to be an S corporation effective for the Year 1 taxable year.
200104017(PDF, 21K)	1/26/2001
The request is for a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund (the "Fund") under the jurisdiction of Commission A. The required information for the schedule of ruling amounts was submitted by Parent and the Taxpayer pursuant to � 1.468A-3(h)(2).
200104016(PDF, 7.1K)	1/26/2001
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.
200104015(PDF, 7.1K)	1/26/2001
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.
200104014(PDF, 12K)	1/26/2001
Requesting a ruling under §1361(e) of the Internal Revenue Code. The information submitted states that Trust was established on Date 1, by A ("Grantor") for the benefit of the living children of the Grantor's child, B, or, failing such living children, for the living children of Grantor's other children. Trust currently holds stock in X, a State corporation, which intends to elect to be an S corporation. Trust represents that: (1) Trust has not made an election to be a qualified subchapter S trust, (2) Trust is not exempt from tax under subtitle A of the Code and (3) each Trust beneficiary is an individual.
200104013(PDF, 12K)	1/26/2001
Requesting a ruling under §1361(e) of the Internal Revenue Code. The information submitted states that Trust was established on Date 1, by A ("Grantor") for the benefit of the living children of the Grantor's child, B, or, failing such living children, for the living children of Grantor's other children. Trust currently holds stock in X, a State corporation, which intends to elect to be an S corporation. Trust represents that: (1) Trust has not made an election to be a qualified subchapter S trust, (2) Trust is not exempt from tax under subtitle A of the Code and (3) each Trust beneficiary is an individual.
200104012(PDF, 16K)	1/26/2001
Requested rulings under � 355 of the Internal Revenue Code. Distributing is an accrual basis State X corporation operating on a 52-53 week fiscal year ending on the Saturday nearest December 31.Controlled is a corporation to be formed under the laws of State X for the purpose of independently operating Business E. Controlled will have outstanding a shares of voting common stock, all of which will be held initially by Distributing.
200104011(PDF, 35K)	1/26/2001
Issues: (1) Whether A qualifies as an insurance company for purposes of deducting net increases in its loss reserves pursuant to Internal Revenue Code � 832. (2) Whether A, a professional corporation in the business of providing medical services, satisfies the all events test so it is entitled to accrue a deduction for services provided by outside medical specialists for which claims for payment have not been submitted.
200104010(PDF, 10K)	1/26/2001
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.
200104009(PDF, 11K)	1/26/2001
Requesting dated April 28, 2000, submitted on behalf of X, which requests relief under §1362(b)(5) of the Internal Revenue Code.
200104008(PDF, 15K)	1/26/2001
Issue: What amount is deductible under § 2053(a)(3) or § 2053(a)(4) and what amount is deductible under § 2056(a) where the Decedent and Spouse held property as tenants by the entirety, and at the time of Decedent's death, Property was subject to a mortgage with respect to which Decedent and Spouse were jointly and severally liable?
200104007(PDF, 9.2K)	1/26/2001
Requesting permission for Taxpayer to revoke its election under § 41(c)(4).
200104006(PDF, 26K)	1/26/2001
Issue: Whether the fraud of a return preparer can be used as the basis for holding the statute of limitations open pursuant to � 6501(c)(1) of the Internal Revenue Code?
200104005(PDF, 15K)	1/26/2001
Requesting a ruling on whether gain from the sale of your client's principal residence would be excluded under � 121 of the Internal Revenue Code .
200104004(PDF, 18K)	1/26/2001
Issue: When does (did) the period of limitations for the assessment of tax with respect to corporation A's S short year expire.
200104003(PDF, 36K)	1/26/2001
Requested rulings as to the federal income tax consequences of a proposed transaction. Distributing is a publicly held corporation organized under the laws of State A. Controlled is a corporation that was organized under the laws of State B. Prior to the transactions described herein, Distributing owned 100 percent of the stock of Controlled. Consequently, Distributing and Controlled propose to restructure its Business 2 subsidiaries into a single entity. Distributing then proposes to separate Controlled from its corporate structure.
200104002(PDF, 19K)	1/26/2001
Issue: Does the Service's failure to treat all which were the subjects of an RCP project alike in the course of determining that some were liable for additional taxes, which may have resulted in some incorrect determinations, provide a cause of action for the affected taxpayers pursuant to Internal Revenue Code § 7433?
200104001(PDF, 59K)	1/26/2001
Request for rulings on certain federal income tax consequences of a proposed transaction. Publicly traded P is the common parent of a consolidated group that conducts Business A and Business B. P proposes to formally separate the assets, personnel, and operations of Business A from those of Business B so that each business may function independently of the other. This separation will result in, among other things, a significant reduction in administrative expense and other costs for each business.
200103074(PDF, 12K)	1/19/2001
Subject: Processing of Offers in Compromise During Collection Due Process Proceedings
200103073(PDF, 12K)	1/19/2001
Issue: Your request presents the issue of whether a taxpayer who uses the standard deduction in computing taxable income for regular tax purposes may use itemized deductions when computing alternative minimum taxable income (AMTI) for alternative minimum tax (AMT) purposes.
200103072(PDF, 14K)	1/19/2001
Issue: May a nonresident alien individual sign an income tax return (Form 1040NR) on behalf of a nonresident alien taxpayer?
200103071(PDF, 69K)	1/19/2001
CBS Branch 1 has approved a modification to Form 668-H, Notice of Federal Estate Tax Lien, to permit that form to be used for the consensual lien created and recorded in connection with an election under Internal Revenue Code § 2057, in addition to the consensual lien created and recorded in connection with a � 2032A election. Until the existing form is reprinted, the phrase "and/or � 2057" will be added by pen and ink to the Notice paragraph of Form 668-H..
200103070(PDF, 14K)	1/19/2001
Concerning which entity is entitled to the � 45B credit when a restaurant obtains its tipped employees from a leasing organization.
200103069(PDF, 14K)	1/19/2001
Requesting technical assistance with respect to the completion of Form 8300 in situations where an individual makes cash payments on behalf of a large group.
200103067(PDF, 10K)	1/19/2001
Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. The information submitted for consideration is substantially as set forth below.
200103066(PDF, 20K)	1/19/2001
Requesting, on behalf of the taxpayers identified above, an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as the common parent of the consolidated group of which Purchaser is a member) and Seller are 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) of the Income Tax Regulations.
200103065(PDF, 20K)	1/19/2001
Requesting, on behalf of the taxpayers identified above, an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as the common parent of the consolidated group of which Purchaser is a member) and Seller are 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) of the Income Tax Regulations.
200103064(PDF, 20K)	1/19/2001
Requesting, on behalf of the taxpayers identified above, an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as the common parent of the consolidated group of which Purchaser is a member) and Sellers are 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) of the Income Tax Regulations.
200103063(PDF, 20K)	1/19/2001
Requesting, on behalf of the taxpayers identified above, an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as the common parent of the consolidated group of which Purchaser is a member) and Seller are 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) of the Income Tax Regulations.
200103062(PDF, 20K)	1/19/2001
Requesting, on behalf of the taxpayers identified above, an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as the common parent of the consolidated group of which Purchaser is a member) and Seller are 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) of the Income Tax Regulations.
200103061(PDF, 8.7K)	1/19/2001
Requesting a ruling that an Arbitration Award (the "Award"), and subsequent payments made pursuant to that Award, did not create a second class of stock under � 1361(b)(1)(D) of the Internal Revenue Code.
200103060(PDF, 18K)	1/19/2001
Requesting, on behalf of the taxpayers identified above, an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as the common parent of the consolidated group of which Purchaser is a member) and Sellers are 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) of the Income Tax Regulations.
200103059(PDF, 18K)	1/19/2001
Requesting, on behalf of the taxpayers identified above, an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200103058(PDF, 8.8K)	1/19/2001
Request on behalf of the Authority for an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to file Form 8328 in order to make a carryforward election under § 146(f) of the Internal Revenue Code ("the Code").
200103057(PDF, 23K)	1/19/2001
Requested rulings under � 355 of the Internal Revenue Code. The taxpayer has proposed the following transaction:(1) Distributing 1 will contribute all of the issued and outstanding stock of Controlled Subsidiary 1 and Controlled Subsidiary 2 to Controlled in exchange for all of the issued and outstanding stock of Controlled.
200103056(PDF, 19K)	1/19/2001
Request rulings as to the federal income tax consequences of a proposed transaction. Acquiring and Target are registered under the Investment Company Act of 1940 (the 1940 Act). For what are represented to be valid business reasons, Acquiring and Target propose the following transaction: (i) Target will transfer all of its assets and liabilities to Acquiring in exchange for an equal value of newly issued Acquiring voting common stock and voting preferred stock.
200103055(PDF, 9.2K)	1/19/2001
Respond to a letter dated August 22, 2000 from your authorized representative requesting a ruling regarding the tax consequences of a proposed transaction under � 336 and 337 of the Internal Revenue Code.
200103054(PDF, 6.9K)	1/19/2001
Requesting that we supplement our letter rulings dated September 13, 1999 (PLR-103429-99) ("Prior Letter Ruling") and April 24, 2000 (PLR-101048-00) ("First Supplemental Letter Ruling").
200103053(PDF, 20K)	1/19/2001
Requesting, on behalf of the taxpayers identified above, an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200103052(PDF, 13K)	1/19/2001
Requesting rulings on behalf of the above referenced taxpayer as to the federal income tax treatment of a proposed transaction. Specifically, rulings were requested under § 305 of the Internal Revenue Code.
200103051(PDF, 83K)	1/19/2001
Issues: (1) Whether T and its related entities may deduct a foreign currency loss under Internal Revenue Code § 988 that does not reflect movements in exchange rates but rather the purchase price of stock. (2) Whether T, who purchased highly appreciated stock, may use � 708(b) and 732(c) to generate a significant tax benefit by engaging in the following tax avoidance transaction: (1) T arranged to have the stock and a cost basis liquid asset put into a foreign partnership; (2) T purchased the partnership; (3) T claimed that the deemed liquidation and basis allocation rules in � 708(b) and 732(c), respectively, thereby increased the adjusted basis of the liquid asset significantly above its fair market value; and (4) T sells the liquid asset and recognizes a large loss.
200103050(PDF, 11K)	1/19/2001
Requesting a ruling under §1361(e) of the Internal Revenue Code. The information submitted states that Trust was established on Date 1, by A ("Grantor") for the benefit of the living children of the Grantor's child, B, or, failing such living children, for the living children of Grantor's other children.
200103049(PDF, 27K)	1/19/2001
Requesting rulings concerning the income, estate, gift, and generation-skipping transfer tax consequences of the proposed division of a trust.
200103048(PDF, 12K)	1/19/2001
Requesting a ruling under §1361(e) of the Internal Revenue Code. The information submitted states that Trust was established on Date 1, by A ("Grantor") for the benefit of the living children of the Grantor's child, B, or, failing such living children, for the living children of Grantor's other children.
200103047(PDF, 12K)	1/19/2001
Requesting a ruling under §1361(e) of the Internal Revenue Code. The information submitted states that Trust was established on Date 1, by A ("Grantor"). Trust currently holds stock in X, a State corporation. X intends to elect to be an S corporation. Trust represents that: (1) Trust has not made an election to be a qualified subchapter S trust, (2) Trust is not exempt from tax under subtitle A of the Code and (3) each Trust beneficiary is an individual.
200103046(PDF, 12K)	1/19/2001
Requesting a ruling, submitted on behalf of Trust, under §1361(e) of the Internal Revenue Code.
200103045(PDF, 12K)	1/19/2001
Requesting a ruling, submitted on behalf of Trust, under §1361(e) of the Internal Revenue Code.
200103044(PDF, 13K)	1/19/2001
Requesting a ruling under §1361(e) of the Internal Revenue Code. The information submitted states that Trust was established on Date 1, by A ("Grantor").
200103043(PDF, 12K)	1/19/2001
Requesting a ruling, submitted on behalf of Trust, under §1361(e) of the Internal Revenue Code.
200103042(PDF, 13K)	1/19/2001
Requesting a ruling under §1361(e) of the Internal Revenue Code. The information submitted states that Trust was established on Date 1, by A ("Grantor"). Trust currently holds stock in X, a State corporation. X intends to elect to be an S corporation.
200103041(PDF, 12K)	1/19/2001
Requesting a ruling under §1361(e) of the Internal Revenue Code. The information submitted states that Trust was established on Date 1, by A ("Grantor").
200103040(PDF, 13K)	1/19/2001
Requesting a ruling, submitted on behalf of Trust, under §1361(e) of the Internal Revenue Code.
200103039(PDF, 6.3K)	1/19/2001
Requesting dated August 28, 2000, that was submitted by your representative on behalf of X, and which requests relief under § 1362(b)(5) of the Internal Revenue Code. FACTS X was incorporated on D1 under the laws of State. X intended to be treated as an S corporation for federal income tax purposes effective on D1, but the S election was not timely filed.
200103038(PDF, 13K)	1/19/2001
Requested a ruling, presented on behalf of C, on the application of § 2703 of the Internal Revenue Code to a proposed amendment to the Articles of Incorporation and Bylaws of C.
200103037(PDF, 21K)	1/19/2001
Requesting rulings about the federal income tax treatment of a proposed and partially consummated transaction. We have received additional information in letters dated August 16, September 28, and October 18, 2000.
200103036(PDF, 7.5K)	1/19/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200103035(PDF, 7.6K)	1/19/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200103034(PDF, 19K)	1/19/2001
Requesting significant subissue rulings in connection with the taxpayer's representations that the transaction qualifies under § 368(a)(1)(F) and § 351 of the Internal Revenue Code (Code).
200103033(PDF, 33K)	1/19/2001
Requesting a ruling, submitted on behalf of Trust, under § 856(d)(1) of the Internal Revenue Code.
200103032(PDF, 11K)	1/19/2001
Requesting a ruling that LLC will not be treated as a separate entity for Federal income tax purposes.
200103031(PDF, 63K)	1/19/2001
Issue: If a � 338(g) election is made in connection with the acquisition of the stock of a foreign corporation, does � 338(h)(16) affect the computation of a selling shareholder's deemed-paid taxes under � 902 and 1248?
200103030(PDF, 8.0K)	1/19/2001
Responds to the ruling request dated August 24, 2000, that you submitted on behalf of X, and which requests relief under § 1362(b)(5) of the Internal Revenue Code. FACTS: X was incorporated on D1 under the laws of State. X intended to be treated as an S corporation for federal income tax purposes effective on D1, but the S election was not timely filed.
200103029(PDF, 7.3K)	1/19/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. FACTS: X was incorporated under State law. X's shareholder intended that X be a subchapter S corporation, effective D1; however, an S corporation election under § 1362 was not timely filed.
200103028(PDF, 7.6K)	1/19/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200103027(PDF, 14K)	1/19/2001
Issue: Where the Service seeks to credit an overpayment shown on an early filed return against an outstanding tax liability from an earlier year, may the credit be deemed to occur prior to the due date for filing the taxpayer's return for the year of the overpayment?
200103026(PDF, 15K)	1/19/2001
Requesting our views on the viability of referring cases to the Department of Justice for lien foreclosure against a taxpayer's interest in a 401(k) plan in the following situation: The taxpayer has received a discharge in bankruptcy, but has an interest in a 401(k) plan that was treated as exempt property in the bankruptcy.
200103025(PDF, 7.4K)	1/19/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. FACTS: X was incorporated under State law. X's shareholders intended that X be a subchapter S corporation, effective D1; however, an S corporation election under § 1362 was not timely filed.
200103024(PDF, 79K)	1/19/2001
Issue: Whether the value of compensatory stock options 1 is a cost that must be shared with affiliates under Treasury Regulation § 1.482-7.
200103023(PDF, 8.9K)	1/19/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation status will be effective as of the taxable year beginning D1.
200103022(PDF, 10K)	1/19/2001
Requesting a ruling under § 1362(f) of the Internal Revenue Code. X was incorporated on Date 1, under the laws of State. X elected to be an S corporation effective Date (1) The current shareholders of X are A, B, and C.
200103021(PDF, 11K)	1/19/2001
Requesting relief under � 1362(b)(5) of the Internal Revenue Code and � 301.9100-3 of the Procedure and Administration Regulations. According to the information submitted, X was incorporated on D1 with A as its sole shareholder. Between D2 and D3, X incorporated SUB1, SUB2, and SUB3 as wholly-owned subsidiaries.
200103020(PDF, 7.5K)	1/19/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. The information submitted discloses that Company was incorporated on a in State. Company has two shareholders, Shareholders. It is represented that Company has intended to be an S corporation since a. However, Company discovered that its S election had not been timely filed.
200103018(PDF, 7.4K)	1/19/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. FACTS: X was incorporated under State law. X's shareholders intended that X be a subchapter S corporation, effective D1; however, an S corporation election under § 1362 was not timely filed.
200103017(PDF, 11K)	1/19/2001
Requesting a ruling concerning the proposed amended and revised deferred compensation plan (the "Plan"), including a supplement providing special provisions regarding temporary, seasonal and part-time employees, which E intends to be an eligible deferred compensation plan under � 457(b) of the Internal Revenue Code of 1986, as amended under � 1447 and 1448 of the Small Business Job Protection Act of 1996. E is represented to be a state governmental entity described in � 457(e)(1)(A) of the Code.
200103016(PDF, 8.1K)	1/19/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. FACTS: X was incorporated on D1, pursuant to the laws of State. X intended to be treated as an S corporation effective D2, but the S election was not timely filed.
200103015(PDF, 36K)	1/19/2001
Requesting of December 22, 1999, for a private letter ruling that Taxpayer's business expense reimbursement program satisfies the substantiation requirements of § 274(d) and the accountable plan requirements of § 62(c) of the Internal Revenue Code.
200103014(PDF, 6.6K)	1/19/2001
This ruling letter is based upon a representation by the taxpayers that they are not using hindsight, as defined in § 301.9100-3(b)(3)(iii) in requesting relief.
200103013(PDF, 6.6K)	1/19/2001
Requesting permission to change its accounting period, for federal income tax purposes. 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.
200103012(PDF, 18K)	1/19/2001
Requesting a ruling that the proposed pro rata partition of Trust into two new trusts, Trust 1 and Trust 2, and the proposed modification in the terms of Trust 1 will not cause the trusts to be subject to the Generation-Skipping Transfer tax imposed by § 2601 of the Internal Revenue Code.
200103011(PDF, 8.7K)	1/19/2001
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 Department of Interior. Facts: Taxpayer, the owner of Building, rehabilitated Building and placed it in service.
200103010(PDF, 34K)	1/19/2001
Issue: Whether a portion of fees paid by Taxpayer to the Department of Energy pursuant to a contract for the disposal of nuclear waste constitutes a contract research expense under Internal Revenue Code § 41(b)(3).
200103009(PDF, 16K)	1/19/2001
Requested rulings regarding your purchase of oil and gas properties. The rulings requested are: (1) A has acquired B's entire economic interest in the properties. (2) The production payment is properly characterized as a purchase money mortgage loan under � 636 of the Code. (3) The Fixed Payment Note is not an economic interest in the properties.
200103008(PDF, 16K)	1/19/2001
Requested rulings regarding your purchase of oil and gas properties. The rulings requested are: (1) A has acquired B's entire economic interest in the properties. (2) The production payment is properly characterized as a purchase money mortgage loan under � 636 of the Code.
200103007(PDF, 21K)	2/21/2001
Requested rulings concerning the income, estate, gift, and generation-skipping transfer tax consequences of a proposed division of each of three trusts into three separate trusts.
200103006(PDF, 36K)	1/19/2001
Issues: (1) Whether advance payments, in the form of Payment A, Payment B, or Payment C, constitute rental income or a reduction in the basis of leased merchandise. (2) Whether such advance payments should be recognized when lease documents are executed or when the documents are processed by Subsidiary. (3) Whether Subsidiary is entitled to change its treatment of Payment C in Year 3 and Year 4, resulting in a reduction of taxable income in both years.
200103005(PDF, 16K)	1/19/2001
Issue: Is Fabricator the manufacturer of fishing lures for purposes of the tax imposed by § 4161(a) of the Internal Revenue Code and therefore liable for this tax on its sales to its customers?
200103004(PDF, 37K)	1/19/2001
Issue: Whether Taxpayer must capitalize under Internal Revenue Code § 263 certain legal and investment banking fees it incurred as the target during a corporate takeover.
200103003(PDF, 27K)	1/19/2001
Requesting rulings concerning the income, estate, gift, and generation-skipping transfer tax consequences of the proposed division of a trust.
200103002(PDF, 27K)	1/19/2001
It is represented that the parties desire to divide Trust into two trusts, Trust 1 and Trust 2, in order to pursue differing investment strategies. The following rulings are requested: (1) The proposed division of Trust into Trust 1 and Trust 2 will not cause the interest of any beneficiary of Trust, Trust 1, or Trust 2 to be includible in such beneficiary's gross estate under § 2033.
200103001(PDF, 27K)	1/19/2001
Requesting rulings concerning the income, estate, gift, and generation-skipping transfer tax consequences of the proposed division of a trust.
200102050(PDF, 7.5K)	1/12/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200102049(PDF, 15K)	1/12/2001
Issue: Are a recipient's record-keeping practices and the presence or absence of account receivable balances determining factors in whether information reporting is required under § 6050I?
200102048(PDF, 15K)	1/12/2001
Issue: The RGS program that the Service uses to prepare a statutory notice of deficiency is not capable of computing the § 6651(a)(1) addition to tax at a rate of 4.5% per month, unless an amount is included in the notice of deficiency for the § 6651(a)(2) addition to tax. Therefore, in order to comply with Chief Counsel Notice N(35)000-169, the Service must manually compute both additions to tax for a majority of § 6020(b) returns.
200102047(PDF, 33K)	1/12/2001
Issue: Can the Service assess penalties under Internal Revenue Code §§ 6701 and 6702 against a person who files frivolous documents with the Service?
200102046(PDF, 138K)	1/12/2001
In an unpublished decision, the Sixth CInternal Revenue Codeuit affirmed that the Service is not required when issuing summonses to follow the taxpayer interview safeguards established by Internal Revenue Code § 7521(b). In Cypress Funds, Inc. v. United States, 2000 U.S. App. LEXIS 27048 (6 th Cir. Oct. 20, 2000) (unpublished), the Sixth CInternal Revenue Codeuit affirmed the enforcement of the Service's summons against the taxpayer's Motion to Quash. The Service issued a summons under � 7602 to the taxpayer's bank, seeking documents and information about the taxpayer. The taxpayer responded, seeking to quash the summons. The taxpayer claimed that the Service failed to satisfy the fourth element of United States v. Powell, 379 U.S. 48 (1964) by not following the administrative steps required by the I.R.C. (specifically, those in � 7521(b)(1)(B)) and because the Service acted in bad faith by relying on a paid informant.
200102045(PDF, 19K)	1/12/2001
Rulings concerning the federal income tax consequences of a proposed transaction. (1) The shareholders of Distributing holding common stock will exchange all of their shares of Distributing for all of the shares of S1 stock. After this exchange, S1 will own an amount of Distributing stock meeting the requirements of § 1504(a)(2) of the Internal Revenue Code.
200102044(PDF, 20K)	1/12/2001
Asking the Internal Revenue Service to rule on the transaction described below. Pursuant to Statute, Company expects that the Finance Order will approve imposition and securitization of the RRB Charge. The RRB Charge is defined as a non-bypassable charge payable by customers, that will yield the amounts necessary to provide for interest on the Securities.
200102043(PDF, 58K)	1/12/2001
Issues: (1) Is the allocation of partnership income and losses between a partner and his former spouse pursuant to a state court order concerning the post-divorce distribution of marital property in a community property regime a partnership item that must be raised in an FPAA? (2) May the Service, in order to disallow a partner's claimed carryback of partnership losses to the years before the Tax Court in the partner's deficiency proceeding for carryback years, contest the amount and validity of losses reported by the partnership in the loss year.
200102042(PDF, 14K)	1/12/2001
Reply to your letter requesting certain rulings with respect to Taxpayer's Employee Stock Purchase Plan (the "Plan") under � 423(b) of the Internal Revenue Code.
200102041(PDF, 10K)	1/12/2001
Response to a letter dated June 15, 2000, requesting a ruling that Corp Y and its subsidiaries be permitted to change to the tax value book method of asset valuation for purposes of apportioning interest expense, beginning with Date B, 2000. Additional information was received in a letter dated July 10, 2000.
200102040(PDF, 14K)	1/12/2001
Response to your letter dated October 5, 1999, and subsequent correspondence requesting a ruling on the generation-skipping transfer tax consequences of a proposed trust reformation.
200102039(PDF, 14K)	1/12/2001
The facts and representations submitted are summarized as follows: On Date 1, prior to January 1, 1990, Grantor transferred $x to A and B as trustees. The trustees were directed to immediately divide the trust corpus into two equal shares. One trust, Trust C, is to be held for the benefit of Grantor's grandchild, C.
200102038(PDF, 12K)	1/12/2001
Target and Acquiring are each domestic, State D and State E corporations, respectively, that are wholly owned subsidiaries of Parent, a publicly traded Country A corporation. Target is engaged in Business B. Acquiring is engaged in Business C and is the common parent of a consolidated group.
200102037(PDF, 9.6K)	1/12/2001
Responds to your letter dated August 14, 2000 submitted on behalf of A, in which you request a ruling under � 7701 of the Internal Revenue Code.
200102036(PDF, 18K)	1/12/2001
Requested, on behalf of the above referenced taxpayer, rulings under � 355 of the Internal Revenue Code.
200102035(PDF, 7.5K)	1/12/2001
Replies to a letter dated March 10, 2000, in which Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement and certifications described in § 1.1503-2(g)(2) with respect to Affiliates #1 and #2 for the tax year ended on Date A.
200102034(PDF, 18K)	1/12/2001
Responds to a letter from Taxpayer's representative dated December 29, 1999. In that letter, Taxpayer requested that certain revisions be made to our ruling dated November 3, 1999 (LTR 200005031, PLR-102566-99) regarding the federal income tax treatment of Taxpayer's prepaid membership fees.
200102033(PDF, 7.6K)	1/12/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200102032(PDF, 7.6K)	1/12/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200102031(PDF, 11K)	1/12/2001
Requesting rulings about the federal income tax consequences of a proposed transaction. The taxpayers represent that the Acquisition Merger, viewed independently of the proposed Upstream Merger, qualified as a reorganization under §§ 368(a)(1)(A) and 368(a)(2)(E) of the Internal Revenue Code.
200102030(PDF, 11K)	1/12/2001
Response to a letter from your authorized representative dated February 10, 2000, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200102029(PDF, 10K)	1/12/2001
Response to your letter dated February 14, 2000, requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200102028(PDF, 19K)	1/12/2001
Responds to a letter submitted on April 18, 2000, on behalf of PRS by your authorized representative requesting a ruling that PRS's proposed acquisition of certain farming operations and its performance of farming services for itself and third parties will be deemed "closely related" and not be deemed a "substantial new line of business" within the meaning of § 1.7704-2(d)(1).
200102027(PDF, 8.0K)	1/12/2001
Responds to your letter, dated August 5, 2000, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation election will be effective as of the taxable year beginning D. FACTS: According to the information submitted, X was incorporated on D and it was decided that X would be an S corporation. The Form 2553, Election by a Small Business Corporation, however, was not timely filed.
200102026(PDF, 8.6K)	1/12/2001
Responds to your letter, dated July 1, 2000, written on behalf of X, requesting a ruling that X's S corporation election will be effective as of the taxable year beginning D2. FACTS According to the information submitted, X was incorporated on D1 and it was decided that X would be an S corporation effective D2. The Form 2553, Election by a Small Business Corporation, however, was not timely filed.
200102025(PDF, 18K)	1/12/2001
Responds to a letter from your authorized representative, dated June 13, 2000, requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election.
200102024(PDF, 9.0K)	1/12/2001
Responds to a letter from your authorized representative dated June 15, 2000, submitted on behalf of Company, requesting a ruling under §§ 1362(d)(3) and 1375(a) of the Internal Revenue Code.
200102023(PDF, 4.9K)	1/12/2001
Responds to a letter dated May 31, 2000, and subsequent correspondence, written on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200102022(PDF, 7.5K)	1/12/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200102021(PDF, 35K)	1/12/2001
Issues: (1) Can the Service levy on a taxpayer's pension plan to fund an offer in compromise? (2) If so, what language should be used for the taxpayer's waiver of the prohibition of levy under Internal Revenue Code § 6331(k)(1)? (3) Can the Service accept from a taxpayer a waiver of the right to receive a notice of intent to levy and the right to a Collection Due Process hearing? (4) Does the taxpayer have equity in the pension plan for purposes of determining the proper amount of an offer if the Service can immediately obtain the funds in the plan by levy?
200102020(PDF, 7.4K)	1/12/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200102019(PDF, 7.5K)	1/12/2001
Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200102018(PDF, 34K)	1/12/2001
Issues: (1) Are the losses reported by the taxpayers in connection with their oil and gas working interests activities conducted through Partnership A passive or nonpassive activity losses for purposes of Internal Revenue Code § 469? (2) Are the losses reported by the taxpayers in connection with their oil and gas working interests activities conducted through the S Corporation passive or nonpassive activity losses for purposes of � 469?
200102017(PDF, 16K)	1/12/2001
Responds to a letter dated April 3, 2000, requesting rulings concerning the federal income tax consequences of a proposed transaction. A previous private letter ruling (TR-31-2494-93) issued to you with regard to § 2055 and 2056 of the Internal Revenue Code is unaffected by the present letter.
200102016(PDF, 47K)	1/12/2001
Issues: (1) Do the Money Laundering Notification Letters consist of, or contain items of, the targets' or businesses' return information, such that disclosure is governed by Internal Revenue Code § 6103? (2) Do the disclosure restrictions imposed by the Privacy Act of 1974, 5 U.S.C. § 552a, apply to the Money Laundering Notification Letters? (3) Is the retention of the Money Laundering Notification Letters in a database, retrievable by the names of the targets and/or recipients, a system of records? If so, what Privacy Act obligations must be followed?
200102015(PDF, 20K)	1/12/2001
Responds to a request for a private letter ruling, dated October 22, 1999, and subsequent submissions filed by you on behalf of Taxpayers. Taxpayers, husband and wife, requested several rulings with respect to the application of � 1400B and 1397B of the Internal Revenue Code to two commercial properties.
200102014(PDF, 20K)	1/12/2001
Requesting a ruling regarding the automatic allocation of Donor's generation-skipping transfer exemption to Trust each time Donor made a gift to Trust, pursuant to § 2632.
200102013(PDF, 11K)	1/12/2001
Response to your letter of February 24, 2000, 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 .
200102012(PDF, 62K)	1/12/2001
Issues: (1) Whether, upon a California court's entry of a judgment of dissolution of marriage which reserves jurisdiction over property issues, community property retains its character as such until division of the property. (2) Whether Internal Revenue Code § 66(b) is applicable to the distributive share of partnership income for years subsequent to the dissolution of the marriage until division of the marital property. (3) Whether the California divorce court order on Date 6 awarding the partnership interest to the petitioner as his separate property is given retroactive effect for federal income tax purposes. (4) Whether petitioner's loss deductions are limited to half of the distributive share of partnership losses attributable to the partnership interest held in his name. (5) Whether petitioner is required to pay tax on half of the partnership distributions he received. Whether petitioner can increase his capital account by amounts that were not allocated to him as partnership income.? (6) Whether petitioner can be held liable as a transferee for his Former wife's taxes. (7) Whether petitioner can be held liable under a fraudulent conveyance theory for partnership distributions made to him that he did not share with his Former wife. (8) Whether the government can argue that petitioner is liable for 100 percent of the distributive share of partnership income because he is judicially estopped from denying that treatment. (9) Whether the government can argue that petitioner is liable for 50 percent of the partnership distributions based on the theory that he misappropriated his Former wife's share of those distributions.
200102011(PDF, 12K)	1/12/2001
Response to a request submitted on behalf of X by its authorized representatives for rulings concerning group term life insurance provided to State and local government employees.
200102010(PDF, 16K)	1/12/2001
In a letter dated May 12, 2000, you requested rulings regarding your purchase of oil and gas properties. The rulings requested are: (1) A has acquired the entire economic interest in the properties. (2) The production payment is properly characterized as a purchase money mortgage loan under � 636 of the Code.
200102009(PDF, 32K)	1/12/2001
Issues: (1) Whether all prior year's underpayments resolved by the settlement payment from Taxpayer to the Department must be included in the computation under Internal Revenue Code § 1341. (2) Whether Taxpayer may calculate its tax under � 1341 by deducting a portion of the settlement payment attributable to some prior years under subsection (a)(4) and by claiming a credit for a portion attributable to other prior years under subsection (a)(5). (3) Whether a portion of the settlement payment should be allocated to interest and excluded from the computation under � 1341.
200102008(PDF, 11K)	1/12/2001
Issue: When must A accrue management fee income from B's. e computation under � 1341.
200102007(PDF, 24K)	1/12/2001
Issue: Whether, under the cInternal Revenue Codeumstances described below, the taxpayer has properly determined amounts to be treated as mine development expenditures under � 616 of the Internal Revenue Code.
200102006(PDF, 9.8K)	1/12/2001
Responds to a letter dated March 20, 2000, from your representative requesting permission, under � 301.9100-(1)(a) of the Procedure and Administration Regulations for an extension of time to make an election under � 263(c) of the Internal Revenue Code for the taxable year ended a.
200102005(PDF, 11K)	1/12/2001
Issue: Whether A is entitled to audit protection under Rev. Proc 92-20, 1992-1 C.B. 685, where a change in method of accounting was made under Internal Revenue Code § 475.
200102004(PDF, 21K)	1/12/2001
Issue: Under the facts of this case, because A impermissibly changed its method of accounting, should the Service deny A's use of the correct method of accounting and return it to its prior erroneous method.
200102003(PDF, 27K)	1/12/2001
Issue: Whether the same amount includible in an employee's W-2 wages from the exercise of nonstatutory stock options and the disqualifying sale of stock obtained through incentive stock options is includible in basic lobbying labor costs for purposes of determining the amount of nondeductible lobbying costs pursuant to the gross-up method under Treasury Regulation § 1.162-28(e)?
200102002(PDF, 19K)	1/12/2001
Issue: Whether the running of the three-year look-back period for determining that a claim is entitled to priority status, as set forth at B.C. § 507(a)(8)(A)(i), is suspended for the time the debtor was making payments pursuant to the terms of a confirmed Chapter 11 plan.
200102001(PDF, 21K)	1/23/2001
Issue: Is the failure to pay a deficiency resulting from a tax year prior to acceptance of an offer in compromise, but for which a notice and demand was issued after acceptance the offer, a violation of the compliance provision of the compromise agreement?
200101033(PDF, 26K)	1/5/2001
Issue: Under what cInternal Revenue Codeumstances can errors to a taxpayer's account be reversed after the expiration of the applicable period of limitations for assessment?
200101032(PDF, 23K)	1/5/2001
Issues: (1) What are the appropriate forms to use to extend the periods for assessment in the three hypothetical situations listed below? (2) What information must be included in the consents to be valid?
200101031(PDF, 28K)	1/5/2001
Issue: If a donor organization fails to include a donor's taxpayer identification number (TIN) when filing the information return required by § 6050L of the Internal Revenue Code (Form 8282), what procedure should the Ogden Service Center follow in determining whether to impose a penalty on that organization under § 6721?
200101030(PDF, 35K)	1/5/2001
Issues: (1) Whether a revenue agent may drive by a taxpayer's house prior to having a reasonable indication that there is a likelihood of unreported income. (2) Whether a revenue agent may conduct a Lexis search to ascertain if the taxpayer purchased real estate during the year(s) at issue prior to having a reasonable indication that there is a likelihood of unreported income.
200101029(PDF, 11K)	1/5/2001
Reply to a letter dated April 20, 2000, and subsequent correspondence, requesting a ruling on behalf of Sponsor. The requested ruling is that Trust, a trust created by Sponsor, will not be classified as a business entity under § 301.7701-2 of the Procedure and Administration Regulations.
200101028(PDF, 7.0K)	1/5/2001
Responds to a letter dated June 6, 2000, and subsequent correspondence submitted by X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200101027(PDF, 7.5K)	1/5/2001
Responds to your authorized representative's letter dated August 25, 2000, submitted on behalf of X requesting relief under � 1362(b)(5) of the Internal Revenue Code. FACTS: X began doing business under State law on D1. The shareholder of X intended that X elect to be treated as an S corporation effective D1. However, the election to be treated as an S corporation was not timely filed.
200101026(PDF, 7.4K)	1/5/2001
Responds to the letter dated August 7, 2000, submitted on behalf of X, requesting relief under § 1362(b)(5) of the Internal Revenue Code. FACTS: X was incorporated under State law on D1. X's shareholder intended that X be a subchapter S corporation, effective D1; however, an S corporation election under § 1362 was not timely filed.
200101025(PDF, 7.3K)	1/5/2001
Responds to a letter dated June 1, 2000, submitted by X's authorized representative on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code.
200101024(PDF, 9.3K)	1/5/2001
Reply to A's letter dated May 17, 2000, and subsequent correspondence, submitted on behalf of X, requesting a ruling under § 1362(f) of the Internal Revenue Code.
200101023(PDF, 23K)	1/5/2001
Reply to your letter dated June 1, 2000, asking the Internal Revenue Service to rule on the transaction described below. FACTS: Parent is the common parent of an affiliated group of corporations that includes Company. Parent files a consolidated return for the group.
200101022(PDF, 15K)	1/5/2001
Responds to a May 31, 2000, and subsequent correspondence, written on behalf of X by its authorized representative, requesting a ruling under § 1362(b)(5) and 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 three subsidiaries as qualified subchapter S subsidiaries (QSUBs) under § 1361(b)(3) of the Code.
200101021(PDF, 19K)	1/5/2001
Response to your letter dated November 24, 1999, and subsequent correspondence, requesting a ruling concerning the estate and gift tax consequences of the creation of a proposed trust (Trust) under §§ 2033, 2038, 2041, 2501, and 2511 of the Internal Revenue Code.
200101020(PDF, 28K)	1/5/2001
Responds to a request dated June 1, 2000 for rulings about the federal income tax treatment of a proposed transaction. We have received additional information in letters dated July 20, 2000, September 11, 2000, and September 21, 2000.
200101019(PDF, 42K)	1/5/2001
Issue: (1) May the Service issue an expedited refund pending the completion of a tax examination after accepting a surety bond to secure the tax to be refunded, if the Service agrees that the taxpayer is entitled to a refund on one or more issues? (2) Given the Internal Revenue Service reorganization, should the discretionary authority to accept a bond posted pursuant to IRM 4.3.5.6.5.3 be changed from the District Director to the Director, Filed Operations, Large and Mid-Sized Business?
200101018(PDF, 7.5K)	1/5/2001
Responds to a letter dated May 16, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200101017(PDF, 14K)	1/5/2001
Reply to a letter dated July 19, 2000, requesting a ruling that each of REMICs 1-7 be granted an extension of time to elect to be treated as Real Estate Mortgage Investment Conduits (REMIC) under � 860D of the Internal Revenue Code.
200101016(PDF, 8.3K)	1/5/2001
Responds to your letter dated June 12, 2000, requesting an extension of time for Company to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property.
200101015(PDF, 13K)	1/5/2001
Response to your letter of June 19, 2000, in which your authorized representative requested a ruling concerning the generation-skipping transfer tax consequences of a proposed division of Trust.
200101014(PDF, 7.5K)	1/5/2001
Responds to a letter dated June 20, 2000, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200101013(PDF, 7.5K)	1/5/2001
Responds to a letter dated June 21, 2000, and subsequent correspondence, requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code.
200101012(PDF, 19K)	1/5/2001
Responds to a letter dated April 12, 2000, and subsequent correspondence submitted on behalf of Trust, requesting rulings under § 856 of the Internal Revenue Code.
200101011(PDF, 21K)	1/5/2001
Response to your letter dated October 8, 1999, and subsequent correspondence submitted on behalf of the trustee of two trusts in which you requested rulings with respect to the inclusion ratios of the trusts for generation-skipping transfer tax purposes.
200101010(PDF, 8.7K)	1/5/2001
Responds to a letter, dated August 10, 2000, written on behalf of X, requesting a ruling under § 1362(b)(5) of the Internal Revenue Code that X's S corporation status will be effective as of the taxable year beginning D1.
200101009(PDF, 11K)	1/5/2001
Respond to your letter dated April 20, 2000, in which you requested that the Commissioner make a determination, under � 1.1502-75(b)(2) of the Income Tax Regulations, that Subsidiaries have joined in the making of the initial consolidated return filed by Parent for the short period October 16, 1997 through December 31, 1997.
200101008(PDF, 14K)	1/5/2001
Respond to your letter dated April 20, 2000, in which you requested that the Commissioner grant Parent and Subsidiaries an extension of time to make a ratable allocation election (the "Election") under § 1.1502-76(b)(2)(ii) of the Income Tax Regulations for the periods January 1, 1998, through November 16, 1998, and November 17, 1998, through December 31, 1998.
200101007(PDF, 73K)	1/5/2001
Issues: (1) Whether the Internal Revenue Code § 1503(d) dual consolidated loss ("DCL") provisions apply to a partnership or a trust that is not a member of a foreign tax group and that is ineligible to file any consolidated group relief election. In particular, whether an entity that does not have a permanent establishment in a foreign country under the foreign country's tax laws and that is not required to file income tax returns in the foreign country is exempt from the § 1503(d) DCL provisions. (2) Whether an entity that is subject to § 1503(d) mirror legislation and, thus, is subject to a foreign country's tax laws that prohibit the net operating losses of the dual resident corporation ("DRC") from offsetting the income of other persons in the foreign country is exempt from the § 1503(d) provisions. (3) Can Parent use the Year 3 and Year 4 net operating losses from the Leasing Arrangements (as described below) to offset the income of other persons within the Parent Consolidated Group?
200101006(PDF, 136K)	1/5/2001
To enable the management of each business to focus exclusively on the needs of its own operation, Distributing proposes to separate the two businesses in the following series of transactions: The Mergers: (i) Sub 18 will merge into Sub 15 ("Merger 1"). (ii) Sub 15 will merge into Sub 2 ("Merger 2"). (iii) Sub 23 will merge into Sub 16 ("Merger 3").
200101005(PDF, 35K)	1/5/2001
Issues: (1) Are the dividends received on Date X and Date Y by DRsub from Fsub in the amounts of $C and $D, respectively, foreign oil and gas extraction income ("FOGEI") as defined in � 907(c) of the Internal Revenue Code? (2) Are the U.K. Advance Corporation Taxes ("ACT") paid by DRsub with respect to the distributions to US parent and surrendered to Fsub to be used to offset its U.K. mainstream corporate tax liability taxes on FOGEI? (3) Are the 5% withholding taxes imposed by the U.K. on the aggregate of the Date Y distribution and ACT refundable credit ("ACT refund") taxes on FOGEI?
200101004(PDF, 50K)	1/5/2001
Issue: Whether the amounts paid by pharmaceutical manufacturers as Medicaid Rebates may be excluded from amount realized on sale and hence from gross income as defined under � 61(a)(3).
200101003(PDF, 48K)	1/5/2001
Issue: Whether the cable television distribution plants rebuilt by the taxpayer are real property for purposes of the interest capitalization provisions in § 263A(f) of the Internal Revenue Code.
200101001(PDF, 20K)	1/5/2001
Issue: Whether the discharge in bankruptcy of certain unsecured debt gives rise to a bad debt deduction under � 166 or whether the debt should be treated as a contribution to capital.

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2001 Chief Counsel'sWritten Determinations

2001 Chief Counsel's
Written Determinations