Chief Counsel's Written Determinations Issued from 200115000 to 200119999

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.

200119064(PDF, 58K)	5/5/2001
This is in response to a letter from your authorized representative (Form 2848), dated March 10, 1999, in which six rulings were requested, all of which related to one or more of the trusts named above as "Q", "R", and "S".
200119063(PDF, 27K)	5/4/2001
This is in reference to your letter of January 30, 2001, requesting advance approval of your grant procedures under � 4945(g) of the Internal Revenue Code.
200119062(PDF, 75K)	5/3/2001
We have considered M's ruling request dated November 24, 1999, as supplemented and modified in a submission dated December 26, 2000. wherein M requested a ruling under � 4943(c)(7) of the Internal Revenue Code for an 18 month extension through May 31, 2001, to dispose of certain excess business holdings resulting from an unusually large gift of stock.
200119061(PDF, 62K)	5/2/2001
This is in reply to A's request and subsequent correspondence for rulings on whether certain transactions by A would result in unrelated business taxable income under � 512 of the Internal Revenue Code.
200119060(PDF, 54K)	5/1/2001
This is in response to the letter submitted on your behalf by your authorized representative, as amended by correspondence dated in which you, through your authorized representative, request several letter rulings under � 72(t) (2) (A) (iv), and 72(t) (4) of the Internal Revenue Code. The following facts and representations support your ruling request.
200119059(PDF, 53K)	4/30/2001
This is in response to the letter, submitted by you, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations. The following facts and representations support your ruling request.
200119058(PDF, 47K)	4/29/2001
This letter is in response to a request for a ruling, dated xxxxx, 2000, as supplemented by correspondence dated xxxxx, 2000, and xxxxx, 2001, submitted on your behalf by your authorized representative, with respect to the federal income tax treatment of certain contributions to Plan X pursuant to � 414(h) (2) of the Internal Revenue Code.
200119057(PDF, 55K)	4/28/2001
This is in response to your letter dated November 13, 2000, in which you requested certain rulings with respect to a proposed transfer of all of the assets of B to C.
200119056(PDF, 53K)	4/27/2001
This is in response to your letter dated November 13, 2000, in which you requested certain rulings with respect to a proposed transfer of all of the assets of B to C.
200119054(PDF, 64K)	5/11/2001
Issues: (1) Is a Form 900 that is signed by an Internal Revenue Service employee other than a Branch Chief, valid? (2) Is a Form 900 that contains an extension date that does not conform to the constraints of Internal Revenue Code § 6502(a), as applicable to requests made on or after January 1, 2000, valid?
200119053(PDF, 21K)	5/11/2001
Issue: Whether the Internal Revenue Code § 6324B special estate tax lien must be released after the 10-year recapture period of I.R.C. § 2032A(c)(1) has elapsed.
200119052(PDF, 14K)	5/11/2001
Issue: When the Service compromises with one party to a joint and several tax liability, what law governs for purposes of determining the effect of that compromise on the liability of the other joint obligor.
200119051(PDF, 21K)	5/11/2001
Requested a ruling and closing agreement that premiums received by Taxpayer on policies of insurance or reinsurance of United States risks are exempt from the insurance excise tax imposed by � 4371 of the Internal Revenue Code pursuant to the Income Tax Convention between the United States and the Government of Ireland ("Convention").
200119050(PDF, 8.6K)	5/11/2001
Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200119049(PDF, 6.3K)	5/11/2001
Parent, a Country W corporation, wholly owns Sub 1 and Sub 2, each of whom are State X corporations. Sub 1 was organized solely for the purpose of being the acquiring corporation in the transaction described below. On Date Y Sub 1 and Target, a State X corporation, entered into a merger agreement pursuant to which Target will merge with and into Sub 1 in exchange for Parent stock and cash ("the Merger"). The transaction was consummated on Date Z.
200119048(PDF, 5.2K)	5/11/2001
The Prior Letter Ruling stated that the business purpose of the spin-off was to facilitate a public offering of Distributing's stock (the "IPO"). Although the proposed distribution has not been effectuated, Distributing has taken substantial steps to undertake the IPO, including engaging an investment banking firm and submitting form S-1 to the Securities and Exchange Commission.
200119047(PDF, 34K)	5/11/2001
Requested rulings on behalf of A concerning the generation-skipping transfer tax, income tax and gift tax consequences of the proposed partition of the Trust. Trust, a testamentary trust, was established for the benefit of A under the will of Decedent-Grantor pursuant to Court Order 1 on date (1) Similar separate testamentary trusts were established for B and C, A's siblings. A and D are the current cotrustees of the Trust.
200119046(PDF, 8.6K)	5/11/2001
Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. lawful permanent residence did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200119045(PDF, 24K)	5/11/2001
A ruling that payments on the swap described below be taken into account in the computation of yield on certain nonpurpose investments of the Issuer for purposes of the yield restriction and arbitrage rebate rules under § 148 of the Internal Revenue Code.
200119044(PDF, 8.1K)	5/11/2001
Requesting a ruling that A's surrender of his U.S. Alien Registration Card (Green Card) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200119043(PDF, 8.6K)	5/11/2001
Requesting a ruling that A's surrender of her U.S. Alien Registration Card (Green Card) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200119042(PDF, 8.7K)	5/11/2001
Submitted by A's authorized representative requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. lawful permanent residence did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200119041(PDF, 6.3K)	5/11/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1. 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.
200119040(PDF, 10K)	5/11/2001
Requesting a ruling under � 1362(f) of the Internal Revenue Code that the termination of Company's S corporation election, if it occurred, was inadvertent. Company represents the following facts. Company was incorporated in State on D1 and elected under � 1362(a) to be an S corporation effective D2. A was Company's sole shareholder.
200119039(PDF, 19K)	5/11/2001
The principal rulings requested are that: (1) Certain mechanical protection contracts issued by Taxpayer are insurance contracts for federal income tax purposes; (2) Taxpayer is an insurance company for federal income tax purposes; and (3) Taxpayer will be entitled to deduct (as reinsurance premiums) amounts paid to an unrelated insurance company in connection with the transactions described below.
200119038(PDF, 17K)	5/11/2001
Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file elections. Parent, the common parent of the consolidated group that includes Sub 1, the United States shareholder of Purchaser, the foreign purchasing company, and of "new" Target, the deemed foreign purchasing company.
200119037(PDF, 25K)	5/11/2001
Revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on May 2, 1989. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2).
200119036(PDF, 23K)	5/11/2001
Relating to certain flexible premium deferred variable annuity contracts (the "AB Contracts") whose owners are enrolled in an asset allocation program (the "ABC Program"). Sister Corp., an affiliate of Taxpayer, administers the ABC Program. You have requested a ruling that, for purposes of determining whether the investments supporting the AB Contracts whose owners are enrolled in the ABC Program are adequately diversified for purposes of § 817(h) of the Internal Revenue Code, the group of assets selected by Sister Corp.
200119035(PDF, 10K)	5/11/2001
Response to your request for a ruling concerning the Worker's status for federal employment tax purposes with respect to services she performs for the Board. The applicable federal employment taxes are those imposed by the Federal Insurance Contributions Act (FICA) and the collection of income tax at source on wages.
200119034(PDF, 25K)	5/11/2001
Revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on June 22, 1999. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2).
200119033(PDF, 8.3K)	5/11/2001
Requesting a ruling under § 1362(f) of the Internal Revenue Code. The information submitted states that X was incorporated on D1. X elected to be an S corporation beginning on D2. On D3, B, a shareholder of X at the time, transferred all B's X stock to Trust (1) A represents that Trust 1 was an eligible S corporation shareholder under § 1361(c)(2)(A)(i).
200119032(PDF, 25K)	5/11/2001
Revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on June 22, 1999. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2).
200119031(PDF, 11K)	5/11/2001
Ruling that the provisions of chapter 13 of the Internal Revenue Code do not apply to any generation-skipping transfers made from the Trust because Decedent was under a mental disability within the meaning of � 26.2601-1(b)(3) of the Generation-Skipping Transfer Tax Regulations from October 22, 1986, until her death.
200119030(PDF, 17K)	5/11/2001
Rulings were requested regarding the estate and generation-skipping transfer tax consequences of a division of a trust into separate trusts. Decedent died testate on Date 1, a resident of State. Decedent was survived by Spouse, who was appointed Executor of Decedent's estate, and two children.
200119029(PDF, 10K)	5/11/2001
Requested a ruling that the provisions of chapter 13 of the Internal Revenue Code do not apply to any generation-skipping transfers made from the Trust because Decedent was under a mental disability within the meaning of � 26.2601-1(b)(3) of the Generation-Skipping Transfer Tax Regulations from October 22, 1986, until her death.
200119028(PDF, 12K)	5/11/2001
Requesting a ruling under §§ 1362(d)(3) and 1375(a) of the Internal Revenue Code. Company, incorporated under the laws of State, elected under § 1362(a) to be an S corporation. It acts as a holding company for two qualified subchapter S subsidiaries (QSubs), Sub A and Sub B. Sub A has accumulated earnings and profits.
200119027(PDF, 14K)	5/11/2001
Requesting a ruling regarding the generation-skipping transfer tax consequences of the amendments to the Trust agreement.
200119026(PDF, 5.2K)	5/11/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 in Year (1) A, as the sole shareholder and president of X, represents that X was intended to be an S corporation beginning Year 1, its first taxable year.
200119025(PDF, 30K)	5/11/2001
Issues: (1) Whether an amended return filed by Holdings to claim a refund for a year for which Corporation filed the original return may be treated as a valid claim under the informal claim theory. (2) Whether amended returns for Years 1 and 2 filed by Holdings to carryback unused research credits arising in Year 3 and exceeding the amount of credits originally claimed on Holdings' Year 3 return may be treated as a valid claim for the excess amount of the credits under the informal claim theory.
200119024(PDF, 6.3K)	5/11/2001
Letter Ruling Request Regarding the Characterization of a Vehicle as a Truck or a Tractor for Federal Excise Tax Purposes. This is a request for a ruling that Taxpayer's first retail sale of a Vehicle will not be subject to the 12 percent excise tax imposed by § 4051(a)(1) of the Internal Revenue Code.
200119023(PDF, 23K)	5/11/2001
Requesting a ruling concerning the generation-skipping transfer tax ("GSTT") consequences of the modification of a trust.
200119022(PDF, 6.1K)	5/11/2001
Requesting a ruling that X's S corporation status will be effective as of D1. X incorporated under State law on D1. X's Shareholders intended that X be a subchapter S corporation for its tax year beginning D1. However, the S corporation election under § 1362 of the Internal Revenue Code was not filed timely.
200119021(PDF, 6.4K)	5/11/2001
Requesting an extension of time pursuant to § 301.9100-3(a) of the Procedure and Administration Regulations to file an election under § 301.7701-3(c) to be disregarded as an entity separate from its owner for federal tax purposes.
200119020(PDF, 6.1K)	5/11/2001
Requesting a ruling that X's S corporation status will be effective as of D1. X incorporated under State law on D1. X's Shareholders intended that X be a subchapter S corporation for its tax year beginning D1. However, the S corporation election under § 1362 of the Internal Revenue Code was not filed timely.
200119019(PDF, 11K)	5/11/2001
Submitted on behalf of Trust, requesting rulings regarding the classification of Trust as a liquidating trust under � 301.7701-4(d) of the Procedure and Administration Regulations. Debtor filed a voluntary petition under Chapter 11 of the Bankruptcy Code in the Bankruptcy Court on D1. On D2, the United States Trustee appointed an Official Committee of Unsecured Creditors ("Creditor's Committee").
200119018(PDF, 7.1K)	5/11/2001
Requesting an extension of time for X to elect under § 754 of the Internal Revenue Code to adjust the basis of partnership property. The grantor of a grantor trust-partner of X died in a. X filed its partnership return for the year of the grantor's death without a § 754 election, having relied on a professional tax return preparer who failed to advise X of the availability and benefits of such an election.
200119017(PDF, 12K)	5/11/2001
Requesting a ruling on the federal tax consequences of the Plan. Employer intends the Plan to be an eligible deferred compensation plan under � 457 of the Internal Revenue Code of 1986. Employer is represented to be an integrated bar whose members consist of all the State X lawyers who are licensed to practice law in State X.
200119016(PDF, 12K)	5/11/2001
Requesting a ruling under subchapter T of the Internal Revenue Code on a transaction described below. Coop was incorporated in b in State A. Coop is engaged principally in the distribution of c products and related general merchandise products. Coop primarily does business with patrons who qualify and have been accepted as "member-patrons."
200119015(PDF, 6.0K)	5/11/2001
Requests relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1. 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.
200119014(PDF, 5.5K)	5/11/2001
The purpose of this letter is to inform you that LTR 200004022 is hereby revoked in accordance with � 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1 (January 2, 2001). LTR 200004022 held that for purposes of � 121 of the Code, that Taxpayer is treated as owning Residence for the period of time that Residence was held in Partnership. We hereby revoke LTR 200004022 because it is not in accord with the current views of the Service.
200119013(PDF, 51K)	5/11/2001
Issue: For purposes of § 20.2031-1(b) of the Estate Tax Regulations, in determining the fair market value of the Corporation stock includible in the Decedent's gross estate, is the Decedent's 50-percent interest includible under � 2033, aggregated with the 44-percent interest subject to Decedent's testamentary general power of appointment and includible under � 2041, and valued as a single 94-percent block?
200119012(PDF, 13K)	5/11/2001
The taxpayer has made the following representations concerning the Contribution and Distribution: (a) The fair market value of the Controlled stock received by Shareholder 1 will approximately equal the fair market value of the Distributing stock surrendered by Shareholder 1 in the exchange.
200119011(PDF, 18K)	5/11/2001
Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent, as the United States shareholder of Purchaser, the foreign purchasing company, and of "new Target," the deemed foreign purchasing company is requesting the extension to file elections under § 338(g) of the Internal Revenue Code and §§ 1.338-1(d) and 1.338-1(g) of the Income Tax Regulations.
200119010(PDF, 9.0K)	5/11/2001
Submitted on behalf of Trust, requesting a ruling concerning the treatment of certain reimbursement payments under § 856 of the Internal Revenue Code.
200119009(PDF, 29K)	5/11/2001
Issue: Whether certain employee benefits paid by Corporation for production employees who performed services in a previous year are subject to capitalization as an indirect production cost.
200119008(PDF, 9.2K)	5/11/2001
Requesting a ruling under § 7704 of the Internal Revenue Code. FACTS X is a publicly traded partnership (PTP) that has made an election under § 7704(g) to remain exempt from § 7704(a). X owns and manages assets that are leased to b. X is listed on E.
200119007(PDF, 118K)	5/11/2001
Issues: (1) Whether "supervisory goodwill" qualifies as "money or other property" for purposes of § 597 of the Internal Revenue Code? (2) Whether the Taxpayer has established a tax basis in supervisory goodwill?
200119006(PDF, 17K)	5/11/2001
Internal Revenue Code § 6321(a) states, "the lien imposed by � 6321 shall not be valid as against any purchaser, holder of a security interest, mechanic's lienor, or judgment lien creditor until notice" has been filed. In this case, M contends that M has a security interest that was in existence and protected under local law against a subsequent judgment lien arising out of an unsecured obligation, even though M's security interest was never perfected by filing.
200119005(PDF, 14K)	5/11/2001
Issue: Is the amount of Company's charitable contribution of its film library reduced under §170(e)(1) of the Internal Revenue Code?
200119004(PDF, 7.3K)	5/11/2001
Taxpayer requests an extension of time under Treasury Regulation § 301.9100-3 to file the election, agreement and annual certification as described in § 1.1503-2(g)(2) for the Tax Years Ended #1, #2, and #3.
200119003(PDF, 18K)	5/11/2001
Issue: When the Service compromises with one party to a joint and several tax liability, which state's law governs for purposes of determining the effect of such compromise on the liability of the other joint obligor.
200119002(PDF, 28K)	5/11/2001
Issue: Whether the Internal Revenue Code § 6662 accuracy-related penalty or the § 6663 fraud penalty may by imposed on Taxpayer for the Year 1 taxable year where the capital losses generated in Year 3 by a partnership formed by Taxpayer, were carried back to Year 1 by Taxpayer's amended return which requested a refund that was not allowed by the IRS.
200119001(PDF, 31K)	5/11/2001
Issue: Whether a Corporate Application for Tentative Refund (Form 1139) is a return for purposes of determining an underpayment under Treasury Regulation § 1.6664-2(a) in applying the Internal Revenue Code § 6662 accuracy-related penalty.
200118057(PDF, 50K)	4/26/2001
This is in response to your request for a ruling that Taxpayer A should treat each automatic payment made pursuant to a systematic withdrawal program adopted with respect to certain deferred variable annuity contracts as part of a series of substantially equal periodic payments within the meaning of � 72(t)(2) of the Internal Revenue Code.
200118056(PDF, 39K)	4/25/2001
This letter is in response to a request for a ruling submitted on Employer M's behalf by its authorized representative, with respect to the federal income tax treatment of certain contributions to Plan X pursuant to � 414(h)(2) of the Internal Revenue Code. In a letter dated xxxxx, 2001, you requested that the ruling pertaining to the pick-up of terminal leave payments be considered under separate cover. This ruling is limited to the proposed pick-up of mandatory employee contributions made pursuant to Proposed Amendment Number One.
200118055(PDF, 502K)	4/24/2001
We have considered B's ruling request dated September 1, 2000, concerning whether a proposed set-aside of E will satisfy the suitability test of � 4942(g)(2)(B)(i) of the Internal Revenue Code and constitute a qualifying distribution under � 4942(g)(l)(A) of the Code.
200118054(PDF, 62K)	4/23/2001
This is in response to your request for rulings as to the federal income tax consequences of your proposed joint venture to operate an ambulatory surgery center.
200118053(PDF, 5K)	4/22/2001
This document has been pulled by the IRS from public view.
200118052(PDF, 11K)	5/9/2001
Issue: Whether Internal Revenue Code 6503(c) permanently extends the collection period of Native Americans who live in Canada but work in the United States.
200118051(PDF, 7.4K)	5/9/2001
Requests an extension of time under Treasury Regulation § 301.9100-3 to file the election and agreement required under § 1.1503-2(g)(2)(i) with respect to losses incurred by Entity for the Tax Years Ended X and Y, and to file the annual certification required under § 1.1503-2(g)(2)(vi) with respect to the losses incurred in Tax Year Ended X. Taxpayer indirectly owned Entity for Tax Years Ended X and Y. Entity incurred losses in both Tax Years Ended X and Y, and these losses were taken into account in computing Taxpayer's consolidated taxable income.
200118050(PDF, 8.4K)	5/9/2001
The Prior Letter Rulings address certain federal income tax consequences of the Distributions by Distributing 2 of the stock of Controlled A and Controlled B and related transactions. To meet capital needs that have developed since the Distributions (which were completed more than 18 months ago), the management of Controlled A has determined that Controlled A should offer to the public a dollars of its common stock (the "Stock Offering").
200118049(PDF, 4.7K)	5/9/2001
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) The sole shareholder of X is A.
200118048(PDF, 4.6K)	5/9/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1. A, the sole shareholder of X, represents that A intended for X to be an S corporation effective D1 and submitted minutes of a meeting of X's directors as evidence of that intent.
200118047(PDF, 8.5K)	5/9/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated in D1 of Year (1) A and B are X's shareholders. A represents that A and B intended for X to be treated as an S corporation for federal tax purposes as of Year 1, X's first taxable year.
200118046(PDF, 24K)	5/9/2001
Requesting that we render several rulings with respect to the incentive stock compensation arrangement proposed by X and its two shareholders. FACTS X is a corporation which has a valid subchapter S election in effect. X has two shareholders, A and B (collectively "the Founders").
200118045(PDF, 76K)	5/9/2001
Distributing is the common parent of a consolidated group, the stock of which is widely held and publicly traded. To solve the management problems and accomplish the separation, Distributing has proposed the following transaction, some of the steps of which have been completed: (i) On Date A and Date B, respectively, Sub 9 and Sub 10 merged with and into Sub 2 in complete liquidation (the "Sub 9 Liquidation" and the "Sub 10 Liquidation", respectively).
200118044(PDF, 8.5K)	5/9/2001
The Prior Letter Rulings address certain federal income tax consequences of the Distributions by Distributing 2 of the stock of Controlled A and Controlled B and related transactions. To meet capital needs that have developed since the Distributions (which were completed more than 18 month ago), the management of Controlled A has determined that Controlled A should offer to the public a dollars of its common stock (the "Stock Offering").
200118043(PDF, 21K)	5/9/2001
Requesting extensions of time under � 301.9100-1 of the Procedure and Administration Regulations to sever a trust into separate trusts, and a determination of the transferors and inclusion ratios, for generation-skipping transfer tax ("GSTT") purposes, of the separate trusts.
200118042(PDF, 11K)	5/9/2001
Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200118041(PDF, 48K)	5/9/2001
Requesting various rulings under � 704, 721, 851 et seq., and 7704 of the Internal Revenue Code. FeederFund1 and FeederFund2 (the "Feeder Funds") were organized as corporations under the laws of State1 on D1. The Feeder Funds intend to qualify for and elect status as regulated investment companies ("RICs") under � 851-855.
200118040(PDF, 47K)	5/9/2001
Requesting various rulings under � 704, 721, 851, and 7704 of the Internal Revenue Code. FeederFund1 and FeederFund2 (the "Feeder Funds") were organized as corporations under the laws of State1 on D1. The Feeder Funds intend to qualify for and elect status as regulated investment companies ("RICs") under � 851-855.
200118039(PDF, 47K)	5/9/2001
Requesting various rulings under � 704, 721, 851 et seq., and 7704 of the Internal Revenue Code. FeederFund1 and FeederFund2 (the "Feeder Funds") were organized as corporations under the laws of State1 on D1. The Feeder Funds intend to qualify for and elect status as regulated investment companies ("RICs") under � 851-855.
200118038(PDF, 15K)	5/9/2001
Requesting income tax and generation-skipping transfer tax rulings concerning the partition of Trust A. Decedent died on Date 1, survived by three children, Child A, Child B, and Child C. Under Decedent's Will, executed on Date 2, Decedent bequeathed the balance of his residuary estate to three testamentary trusts, with each separate trust for the primary benefit of one child. This ruling concerns Trust A, created for the benefit of Child A.
200118037(PDF, 21K)	5/9/2001
Requesting an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to make a "reverse" qualified terminable interest property ("QTIP") election under � 2652(a)(3) of the Internal Revenue Code with respect to the assets of the Marital Deduction Trust.
200118036(PDF, 9.6K)	5/9/2001
Request, submitted on behalf of A by A's authorized representative, for an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations. Specifically, A has requested extensions of time to file Forms 970, Application To Use LIFO Inventory Method, on behalf of B and C for B's and C's 52-53 tax years ended Date 1.
200118035(PDF, 5.6K)	5/9/2001
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. Company has one shareholder, Shareholder. It is represented that Company has intended to be an S corporation since b. However, Company discovered that its S election had not been timely filed.
200118034(PDF, 6.1K)	5/9/2001
Requesting a ruling that X's S corporation status will be effective as of D1. X incorporated under State law on D1. X's Shareholders intended that X be a subchapter S corporation for its tax year beginning D1. However, the S corporation election under § 1362 of the Internal Revenue Code was not filed timely. X requests a ruling that it will be recognized as a subchapter S corporation effective D1 pursuant to § 1362(b)(5).
200118033(PDF, 4.6K)	5/9/2001
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) The sole shareholder of X is A. A, X's president, represents that it was A's intent that X elect S corporation status effective D1 of Year 1.
200118032(PDF, 4.8K)	5/9/2001
Submitted on behalf of X, 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 represent that A is the sole shareholder of X. A, the president of X, further represents that it was intended for X to be an S corporation beginning in Year 1, its first taxable year.
200118031(PDF, 25K)	5/9/2001
Rulings regarding application of the rules for a qualified personal residence trust under § 2702 of the Internal Revenue Code. Taxpayer is a citizen of Country. Taxpayer was employed by Company 1 in Country, and over the course of his career he accepted various positions that required his relocation to other countries.
200118030(PDF, 6.2K)	5/9/2001
Requesting a ruling that X's S corporation status will be effective as of D1. X incorporated under State law on D1. X's Shareholders intended that X be a subchapter S corporation for its tax year beginning D1. However, the S corporation election under § 1362 of the Internal Revenue Code was not filed timely. X requests a ruling that it will be recognized as a subchapter S corporation effective D1 pursuant to § 1362(b)(5).
200118029(PDF, 6.1K)	5/9/2001
Requesting a ruling that X's S corporation status will be effective as of D1. X incorporated under State law on D1. X's Shareholder intended that X be a subchapter S corporation for its tax year beginning D1. However, the S corporation election under § 1362 of the Internal Revenue Code was not filed timely.
200118028(PDF, 6.6K)	5/9/2001
Requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations. According to the information submitted, X was validly formed under Country law on D1 and began operations on D2. Further, X and X's shareholders intended from inception to elect to classify X as a partnership for federal tax purposes. However Form 8832, Entity Classification Election, was not timely filed.
200118027(PDF, 5.8K)	5/9/2001
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 by S1 and S2. Company currently has two shareholders, Shareholders. It is represented that Company has intended to be an S corporation since its incorporation.
200118026(PDF, 6.0K)	5/9/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date (1) The sole shareholder of X desired that X elect S corporation treatment effective on Date 2, but the election to be treated as an S corporation was not timely filed.
200118025(PDF, 8.0K)	5/9/2001
Requesting a ruling under § 1362(f) of the Internal Revenue Code. The information submitted states that X was incorporated D1 and elected to be S corporation effective D2. On D3, X issued z shares of X to IRA, an individual retirement account for the benefit of A.
200118024(PDF, 5.2K)	5/9/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 in Year (1) A, as the president of X, represents that X was intended to be an S corporation beginning Year 1, its first taxable year.
200118023(PDF, 6.6K)	5/9/2001
Taxpayer requests a ruling that acquisition of an exchange accommodator (QI), which, as an LLC, is a disregarded business entity for federal tax purposes, will be treated as the acquisition of qualifying like-kind replacement property.
200118022(PDF, 4.8K)	5/9/2001
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 is the sole shareholder of X. A, the president of X, represents that it was intended for X to be an S corporation beginning in Year 1, its first taxable year.
200118021(PDF, 5.1K)	5/9/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1. A, the vice-president of X, represents that it was intended for X to be an S corporation effective as of D2 of Year 1, its first taxable year.
200118020(PDF, 5.0K)	5/9/2001
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 is the sole shareholder of X. A, the president of X, represents that it was intended for X to be an S corporation beginning in Year 1, its first taxable year.
200118019(PDF, 4.9K)	5/9/2001
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 is the sole shareholder of X.
200118018(PDF, 10K)	5/9/2001
The Prior Letter Ruling addresses a distribution of Controlled stock by Distributing under § 355 of the Internal Revenue Code (the "Spin-Off"), followed by a merger of Acquired into Controlled (the "Merger"). The Spin-Off and Merger were completed on Date A. In preparation for these transactions, Controlled had recapitalized its single class of common stock into Class A common stock and Class B common stock (the "First Recapitalization").
200118017(PDF, 5.7K)	5/9/2001
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 three shareholders, Shareholders. It is represented that Company has intended to be an S corporation since a.
200118016(PDF, 24K)	5/9/2001
Issue: Whether the Internal Revenue Service's notification to the Department of Labor was sufficient for purposes of Internal Revenue Code §4975(h) as to Employer A and Individuals B, C and D.
200118015(PDF, 15K)	5/9/2001
Issue: Whether residents of East Timor qualify for benefits under the Convention Between the Government of the United States and the Government of the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (United States-Indonesia Income Tax Treaty).
200118014(PDF, 6.7K)	5/9/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date (1) The shareholder of X desired that X elect S corporation treatment effective on Date 1, but the election to be treated as an S corporation was not timely filed.
200118013(PDF, 6.1K)	5/9/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date (1) The shareholder of X desired that X elect S corporation treatment effective on Date 1, but the election to be treated as an S corporation was not timely filed.
200118012(PDF, 6.4K)	5/9/2001
Request a ruling whether X and Y are liable for the gasoline tax imposed by § 4081 of the Internal Revenue Code on the removal of racing fuel from their refinery racks. X and Y have represented the following. X and Y operate refineries where they produce fuel that is used exclusively in race vehicles and boats (the racing fuel). The racing fuel has an octane level of 110, contains lead in excess of that permitted by the Environmental Protection Agency (EPA), and does not have detergent additives that the EPA requires for gasoline.
200118011(PDF, 9.7K)	5/9/2001
Requesting rulings regarding the federal income tax consequences of a proposed transaction. We received additional information in a letter dated October 12, 2000. Mutual Bank is a federally-chartered insured mutual savings bank engaged in banking and banking related business under the laws of State A. Mutual Bank has no authorized capital stock. Instead, holders of Mutual Bank's deposit accounts have liquidation and voting rights in Mutual Bank.
200118010(PDF, 10K)	5/9/2001
Ruling on the reinvestment of proceeds under § 1033 of the Internal Revenue Code. It is represented that each Taxpayer has for some time held as an investment a noncontrolling interest (ranging from a minimum of d % to a maximum of e %) in the stock of Company, a privately owned, state regulated utility. Company provided f for end use by customers in g.
200118009(PDF, 31K)	5/9/2001
Issue: For purposes of the transitional netting rule under � 1.1502-20(c)(2)(v) ("transitional netting rule"), does the baseline for determining the net increase in the basis of a share of subsidiary stock include the subsequent purchases of additional stock and contributions to capital described below?
200118008(PDF, 5.4K)	5/9/2001
Request for a ruling to determine the federal employment tax status of the above-named worker with respect to services he provided to the firm for the period from February 3, 1997 to February 3, 1999. The federal employment taxes are those imposed by the Federal Insurance Contributions Act (FICA), the Federal Unemployment Tax Act (FUTA), and the Collection of Income Tax at Source on Wages.
200118007(PDF, 7.5K)	5/9/2001
Requesting permission for Taxpayer to revoke its election under § 41(c)(4). This letter is in response to that request. For the tax year ending on x, Taxpayer elected to determine its credit for increasing research activities (research credit) under the alternative incremental research credit rules of § 41(c)(4).
200118006(PDF, 12K)	5/9/2001
Requesting, on behalf of the taxpayers identified in the above legend, an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent requests an extension of time for Parent, Sub 1, and Sub 2 to make an election to file a consolidated federal income tax return, with Parent as the common parent, under § 1.1502-75(a)(1) of the Income Tax Regulations (hereinafter referred to as "the Election"), effective for their taxable year ending on Date A.
200118005(PDF, 16K)	5/9/2001
You have asked us to review the draft Forms 870-P for the above-named taxpayer. We believe the determinations reached in this case are appropriate. However, we recommend that additional language be included in the Explanation of Adjustments portion of the Forms 870-P to further explain our reasons for such determinations and to strengthen our litigating position.
200118004(PDF, 15K)	5/9/2001
Business Purpose and Proposed Transaction Because of disputes between Family A and Family F regarding the direction and operation of Distributing, the following transaction has been proposed to place Business Y under the control of Family A operating Business Y and Business X under the control of Family F: (i) Distributing will transfer the Business X assets to newly formed Controlled in exchange solely for Controlled stock and the assumption by Controlled of related liabilities (the "Contribution").
200118003(PDF, 23K)	5/9/2001
Issue: May a surviving spouse filing a joint return with a decedent for the decedent's year of death use accumulated net operating losses (NOL) arising pre-bankruptcy when the individual debtor dies before (but in the same calendar year as) his bankruptcy estate is terminated?
200118002(PDF, 25K)	5/9/2001
Issue: Whether, under the doctrine of equitable recoupment, the estate is precluded from including Year 1 gifts in computing the total gift tax payable under Internal Revenue Code § 2001(b)(2) when the Year 1 gifts were not included in calculating gift taxes paid for taxable years Year 2, Year 3, and Year 4, and the statute of limitations bars assessment of gift taxes for those years.
200118001(PDF, 42K)	5/9/2001
Issue: Whether the Service must pay interest under § 6611(a) on overpayments of special estimated tax payments made pursuant to § 847(2) of the Code.
200117046(PDF, 35K)	4/21/2001
This is in reply to your letter of August 1, 2000, requesting advance approval of your grant making procedures pursuant to the provisions of � 4945 of the Internal Revenue Code and that. certain other grants to individuals are not taxable expenditures within the meaning of � 4945(d)(3) of the Code.
200117045(PDF, 63K)	4/20/2001
This is in response to a letter as amended by letters submitted on your behalf by your authorized representative, in which a private letter ruling was requested under � 72 of the Internal Revenue Code . Your authorized representative submitted the following facts and representations:
200117044(PDF, 69K)	4/19/2001
This is in response to a letter as amended by letters submitted on your behalf by your authorized
200117043(PDF, 61K)	4/18/2001
This is in response to your request for rulings as to the federal income tax consequences of a proposed joint venture to operate an ambulatory surgery center.
200117042(PDF, 111K)	4/17/2001
This letter responds to x's request dated August 8, 2000 for rulings pertaining to proposed transactions involving the administration of an estate, reorganization of a private foundation, and settlement payments to a disqualified person from a corporation in which a private foundation has an interest.
200117041(PDF, 51K)	4/16/2001
This is in reply to the letter of April 12, 2000, concerning the proposed transfer of all or substantially all of Z's assets to X and Y.
200117040(PDF, 25K)	4/27/2001
Issues: (1) Whether a third party contact must be initiated 10 days after the issuance of Letter 3164, or whether more time can be granted to allow taxpayers outside the United States ample time to receive the notice prior to the commencement of the third party contact. (2) Whether contact with the competent authority of a treaty partner for purposes of verifying a taxpayer's entitlement to treaty benefits is a third party contact within the purview of � 7602(c). (3) Whether contact by the Virgin Islands for a cover over of taxes is a third party contact under � 7602(c). (4) Whether contact with an unauthorized agent for purposes of identifying a taxpayer is a third party contact under � 7602(c).
200117039(PDF, 49K)	4/27/2001
Issues: In your incoming memorandum, you requested guidance on several issues arising in transactions detected by the lease stripping ISP. Your questions concerning whether the transactions should be disregarded because they lack economic substance and transferee liability were addressed in an FSA dated October 16, 2000. Your question concerning the application of � 482 is being addressed separately by CC:INTL and CC:APJP, respectively. Your remaining questions, addressed in this TA are: (1) Do the transactions qualify as � 351 exchanges? (2) If the transactions are � 351 exchanges, what is the transferor's basis in the stock acquired in the exchange?
200117038(PDF, 31K)	4/27/2001
A municipality has a group-term life insurance plan. The employer pays for the cost of insurance coverage under $50,000. The employee may purchase additional insurance which may exceed $50,000. Is any part of the premium taxable?
200117037(PDF, 18K)	4/27/2001
Issue: If a debtor in a Chapter 13 bankruptcy has received an erroneous refund for a post-bankruptcy petition tax year, can the Memphis Service Center request repayment of the erroneous refund without violating the automatic stay imposed by the bankruptcy?
200117036(PDF, 13K)	4/27/2001
Issue: Whether, under the cInternal Revenue Codeumstances described below, a Faxed copy of a taxpayer's signature is an acceptable signature for purposes of � 6061 and 6065 of the Internal Revenue Code.
200117034(PDF, 14K)	4/27/2001
Issues: 1) If the Service continues to send CP-71 annual reminder notices to a taxpayer who has filed a request for innocent spouse relief, is the Service violating the prohibition on certain collection activity which is imposed, once such a request is filed, by Internal Revenue Code § 6015(e)(1)(B)(i)? 2) Given that the annual reminder notices are required to be sent pursuant to I.R.C. § 7524, can the Service legally decide not to send them to a taxpayer who has filed a request for innocent spouse relief?
200117033(PDF, 14K)	4/27/2001
Issue: How should the Internal Revenue Service dispose of nine handguns and two collectible guns that were seized from Criminal Investigation ("CI") by Compliance?
200117032(PDF, 11K)	4/27/2001
Requesting a ruling that REMIC 3 be granted an extension of time to elect to be treated as a Real Estate Mortgage Investment Conduit (REMIC) under � 860D of the Internal Revenue Code.
200117031(PDF, 12K)	4/27/2001
Written on behalf of Company by its authorized representative, requesting a ruling under § 1362(f) of the Internal Revenue Code. Company incorporated on d1 under State law, and filed an election under § 1362(a) to be treated as an S corporation on d2. On d3, SH1, a Company shareholder, transferred x shares of Company's stock to Trust 1.
200117030(PDF, 10K)	4/27/2001
Requesting a ruling on behalf of Trust. You have requested a ruling that Trust be granted an extension of time to elect to be treated as a Real Estate Mortgage Investment Conduit (REMIC) under � 860D of the Internal Revenue Code.
200117029(PDF, 5.0K)	4/27/2001
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 and B are the shareholders of X.
200117028(PDF, 4.7K)	4/27/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1 of Year (1) The shareholders of X are A, B, C, and D. A, X's president, represents that it was the shareholders intent to have X elect to be an S corporation effective D1 of Year 1, but the Form 2553, Election by a Small Business Corporation, for X was not timely filed.
200117027(PDF, 8.0K)	4/27/2001
Requesting a ruling that A's renunciation of his 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.
200117026(PDF, 25K)	4/27/2001
Request submitted by your authorized representatives for a ruling about the effect on the Bonds of certain aspects of the electric industry restructuring within State. Bondholder is the holder of least one of the Bonds. The Bonds were issued for the benefit of Company.
200117025(PDF, 14K)	4/27/2001
Request was made for an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to make an election. Parent as the common parent of the consolidated group of which Sub was a member is requesting the extension to file a statement of allowed loss under § 1.1502-20(c)(3) of the Income Tax Regulations (sometimes hereinafter referred to as the "Statement" or the "Election").
200117024(PDF, 6.3K)	4/27/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. FACTS X was incorporated on D1. 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.
200117023(PDF, 6.0K)	4/27/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date (1) The shareholders of X desired that X elect S corporation treatment effective on Date 1, but the election to be treated as an S corporation was not timely filed.
200117022(PDF, 5.8K)	4/27/2001
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.
200117021(PDF, 12K)	4/27/2001
Requesting a ruling that Property meets the requirements of a personal residence under § 2702 of the Internal Revenue Code and § 25.2702-5(c)(2)(i)(B) of the Gift Tax Regulations.
200117020(PDF, 81K)	4/27/2001
Issues: (1) Whether certain transfers of stock in a parent corporation, by a subsidiary, to the parent's employees are distributions under §§301, et seq., of the Internal Revenue Code. (2) Whether these transfers are capital contributions under §1.83-6(d) of the Income Tax Regulations. (3) Whether these transfers lack sufficient economic substance to support the claimed tax benefits.
200117019(PDF, 75K)	4/27/2001
Issues: (1) To what extent, if any, is Corporation B entitled to benefits under the U.S.-Country I income tax treaty ("Treaty" or "Country I Treaty") in light of the inconsistent treatment claimed for domestic law purposes and the purpose and intent of the Treaty? (2) If it is determined that Corporation B is entitled to an income exclusion under the Treaty, may the Service deny credit for foreign taxes paid and deemed paid by Corporation B on or with respect to the excluded income? (3) Is the transaction an outbound transaction that is itself a taxable event for U.S. Federal tax purposes?
200117018(PDF, 8.3K)	4/27/2001
Requesting a ruling that Corp A and its subsidiaries be permitted to change to the tax book value method of asset valuation for purposes of apportioning interest expense for tax years beginning on or after Date 0, 1999.
200117017(PDF, 9.5K)	4/27/2001
Requested a ruling on the federal income tax consequences under � 451 and 404 of the Internal Revenue Code with respect to the Plan. The Company has established the Plan, a nonqualified deferred compensation plan, to provide retirement benefits to key management personnel in order to provide employees with an incentive to remain with the Company and to perform to the best of their abilities.
200117016(PDF, 42K)	4/27/2001
Requested rulings under Internal Revenue Code §§ 302(b)(3), 305 and 4941. X is a personal holding company. Its primary business is to manage its portfolio of marketable securities, which is its principal asset.
200117015(PDF, 4.7K)	4/27/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1. A, the chief executive officer of X represents it was intended that X be an S corporation effective D1 and submitted minutes of X's first meeting of its directors as evidence of that intent.
200117014(PDF, 4.7K)	4/27/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1. A, the chief executive officer of X represents it was intended that X be an S corporation effective D1 and submitted minutes of X's first meeting of its directors as evidence of that intent.
200117013(PDF, 4.9K)	4/27/2001
Requesting a ruling under § 1362 of the Internal Revenue Code. The information provided indicates that S, T, U, V, W, X, and Y (the "Corporations") are each S corporations.
200117012(PDF, 4.7K)	4/27/2001
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) The shareholders of X are A, B, and C.
200117011(PDF, 5.8K)	4/27/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1 and intended to make an election to be treated as an S corporation effective on D2, but the S election was not timely filed.
200117010(PDF, 7.2K)	4/27/2001
Requesting an extension of time for Company to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be treated as an association taxable as a corporation.
200117009(PDF, 4.8K)	4/27/2001
Submitted on behalf of X, 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) The sole shareholder of X is A.
200117008(PDF, 26K)	4/27/2001
Issues: (1) Whether a series of transactions involving Corporation A, Corporation B, and their common shareholders may be characterized as a reorganization under � 368(a)(1)(D) of the Internal Revenue Code . (2) Alternatively, whether the transactions may be characterized as a reorganization under � 368(a)(1)(F) of the Code.
200117007(PDF, 18K)	4/27/2001
Submitted on behalf of Decedent's estate, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to: (1) make a qualified terminable interest property (QTIP) election under § 2056(b)(7) of the Internal Revenue Code.
200117006(PDF, 14K)	4/27/2001
Requesting a ruling that, for purposes of determining gain or loss at the time of sale, the adjusted basis of the property sold includes the unamortized research and experimental expenditures deferred under § 59(e) of the Internal Revenue Code.
200117005(PDF, 23K)	4/27/2001
Issue: Whether an executor of a deceased spouse's estate may elect the application of � 6015(b) and 6015(c) on behalf of a deceased individual?
200117004(PDF, 23K)	4/27/2001
Issue: Is Buyer entitled to include in its basis the amounts paid by Target to Seller for Seller's Target stock?
200117003(PDF, 14K)	4/27/2001
Subject: Form SS-8 Submissions Involving Partnership Issues This memorandum responds to questions raised by a number of Forms SS-8 submissions involving partnership issues.
200117002(PDF, 28K)	4/27/2001
Requesting rulings on the proper income and generation-skipping transfer tax treatment of the proposed partition of a trust into separate trusts.
200117001(PDF, 23K)	4/27/2001
Issue: You requested our views regarding extensions of the statute of limitations on collection under Internal Revenue Code § 6502(a), as amended by the I.R.S. Restructuring and Reform Act of 1998, P.L. 105-206, § 3461(a)(1)-(2) (July 22, 1998).
200116058(PDF, 44K)	4/15/2001
This is in response to the letter, submitted by your authorized representative in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations. The following facts and representations support your ruling request.
200116057(PDF, 36K)	4/14/2001
This is in response to the letter, submitted by your authorized representative, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations. The following facts and representations support your ruling request.
200116056(PDF, 32K)	4/13/2001
This is in response to a letter dated July 28, 2000, as supplemented letters of October 12, 2000 and November 28, 2000, in which you, through your authorized representative, request rulings under � 408(d)(6) and 72(t)(4)(A)(ii) of the Internal Revenue Code. The following facts and representations support your ruling request.
200116055(PDF, 54K)	4/12/2001
This letter is in reply to a request for a letter ruling dated December 29, 1998, as supplemented by submissions of September 24, 1999, and July 28, 2000, made on behalf of Employer M, concerning the federal tax treatment of certain contributions made to Plan X and Plan Y under � 414th) (2) of the Internal Revenue Code
200116054(PDF, 27K)	4/11/2001
This is in reply to your ruling request of July 31, 2000, requesting approval of a set-aside of your income under the suitability test of � 4942(g)(2)(B)(i) of the Internal Revenue Code and � 53.4942(a)-3(b)(2) of the Foundation and Similar Excise Taxes Regulations.
200116053(PDF, 40K)	4/10/2001
This is in response to the letter, submitted by your authorized representative on your behalf, in which you request relief under � 301.9100-3 of the Procedure and Administration Regulations.
200116052(PDF, 73K)	4/9/2001
This is in response to your letter dated October 12, 1999, as supplemented by correspondence dated September 14, 2000, November 27, 2000, and January 9, 2001, which was submitted by your authorized representative on your behalf, with respect to the applicability of � 403(b) of the Internal Revenue Code to Plan X.
200116051(PDF, 33K)	4/8/2001
This is in response to a request for a private letter ruling, dated June 16, 2000, as supplemented by a letter dated January 9, 2001, submitted on your behalf by your authorized representative, concerning the applicability of � 409(l)(4) of the Internal Revenue Code to an employee stock ownership plan. Your authorized representative submitted the following facts and representations in support of the request.
200116050(PDF, 32K)	4/7/2001
This is in response to your May 17, 1999, request for a private letter ruling, as supplemented by correspondence dated October 26, 2000, concerning whether Agency A may establish a 401(k) plan for the benefit of Gmup B Members who are employees of Agency A. The following facts and representations have been submitted in support of your ruling.
200116049(PDF, 90K)	4/6/2001
This is in response to a ruling request submitted by your authorized representative dated September 16, 2000, as supplemented by correspondence dated December 22, 1999, July 26, 2000, July 27, 2000, August 21, 2000, August 30, 2000, September 13, 2000, November 21, 2000, December 8, 2000, and January 18, 2001, with respect to the federal income tax treatment of certain contributions to Plan X under � 414(h) (2) of the Internal Revenue Code.
200116048(PDF, 51K)	4/5/2001
This is in reply to your rulings request of September 11, 2000, on C's proposed transfer of all of its assets to T pursuant to � 507(b)(2) of the Internal Revenue Code.
200116047(PDF, 58K)	4/4/2001
We have considered your ruling request dated 3, as modified and supplemented. You (the "Foundation") have requested a series of rulings that certain transactions with related entities are not subject to the taxes on self-dealing under � 4941 of the Internal Revenue Code.
200116046(PDF, 56K)	4/3/2001
This is in response to your ruling request submitted on your behalf by your authorized representative dated July 23, 1999, and supplemented by additional correspondence dated January 11, 2000, June 23, 2000, September 8, 2000, October 27, 2000, January 8, 2001, and January 16, 2001. The ruling request concerns the tax treatment of elective deferrals to a cash or deferred arrangement in coordination with a nonqualified deferred compensation plan.
200116045(PDF, 25K)	4/2/2001
This is in reference to your letter of November 15, 2000, requesting a ruling that grants made under the program described will not constitute taxable expenditures within the meaning of � 4945(d)(3) and that amounts distributed to students will constitute scholarship grants within the meaning of � 117(a).
200116044(PDF, 15K)	4/20/2001
Response to the question Mr. Provenzale posed in an e-mail, dated December 5, 2000. He specifically asked whether the rationale of Treasury Regulation § 301. 6331-1(c) would permit Form 668-C, Final Demand, to be served by mail. We believe the service of a Form 668-C could be accomplished by mailing if the Form 668-C were modified to reflect such service.
200116043(PDF, 23K)	4/20/2001
The issue is whether certain costs incurred in the construction and reconstruction of golf courses qualify as land improvements eligible for depreciation.
200116042(PDF, 8.7K)	4/20/2001
Requesting an extension of time to make a retroactive election under � 1.197-1T(c) of the Temporary Income Tax Regulations. Taxpayer acquired a franchise in D2, by paying $X as a franchise fee. Taxpayer did not make a retroactive election on their tax return for the taxable year ended D3 for their acquisition of the franchise.
200116041(PDF, 20K)	4/20/2001
Requests a ruling regarding the treatment under §§ 1.832-4(a)(4) through (8) of the Income Tax Regulations of premium stabilization reserves which Taxpayer maintains in conjunction with certain group accident and health insurance contracts.
200116040(PDF, 25K)	4/20/2001
Requesting rulings on behalf of the Fund concerning whether certain disability and survivor benefits received under the Statute are excludable from gross income under � 104(a)(1) of the Internal Revenue Code .
200116039(PDF, 5.0K)	4/20/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated in Year 1.
200116038(PDF, 5.7K)	4/20/2001
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.
200116037(PDF, 5.6K)	4/20/2001
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.
200116036(PDF, 5.7K)	4/20/2001
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.
200116035(PDF, 7.8K)	4/20/2001
Requesting a ruling, under � 877(c) of the Internal Revenue Code of 1986 , that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200116034(PDF, 7.7K)	4/20/2001
Requesting a ruling, under � 877(c) of the Internal Revenue Code of 1986 , that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200116033(PDF, 6.5K)	4/20/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. According to the information submitted, X was incorporated under State law on D1, and it was decided that X would be an S corporation.
200116032(PDF, 12K)	4/20/2001
Request that the Service, pursuant to � 7805(b)(8)1, make the partial revocation of PLR 9441020 effective as of the beginning of Tax Year (3) The following specific deductions for Tax Year 1 will be treated as part of Taxpayer's consolidated specified liability loss: a) allowable deductions for interest expense resulting from federal tax deficiencies relating to tax years at least 3 years prior to Tax Year 1.
200116031(PDF, 13K)	4/20/2001
Requesting a ruling regarding the effect of the judicial construction of a trust instrument for federal generation-skipping transfer tax purposes.
200116030(PDF, 8.2K)	4/20/2001
Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. lawful permanent residence did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200116029(PDF, 8.2K)	4/20/2001
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.
200116028(PDF, 20K)	4/20/2001
Regarding the federal income tax consequences of a proposed transaction. Pursuant to the plan, Acquiring and Target propose the following transaction (the "Reorganization"): (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. No fractional shares will be issued, due to the expense and inconvenience of issuing and transferring fractional shares.
200116027(PDF, 6.9K)	4/20/2001
Requesting that you be granted an extension of time under Treasury Regulation § 301.9100-3 to elect the foreign earned income exclusion for the Tax Years at Issue.
200116026(PDF, 4.7K)	4/20/2001
Application to Adopt, Change, or Retain a Tax Year, submitted on behalf of the above-named taxpayer, requesting permission to change its accounting period, for federal income tax purposes.
200116025(PDF, 19K)	4/20/2001
Rulings were requested regarding certain federal income tax consequences of a proposed transaction. Accordingly, the following transaction has been proposed: (1) On the date of the Distribution (described below), Distributing will contribute to Controlled all of the assets of business b in exchange for 100 percent of the outstanding common stock of Controlled and the assumption by Controlled of the liabilities relating to business b.
200116024(PDF, 19K)	4/20/2001
Requested as to the federal income tax consequences of a transaction consummated on Date R. Distributing is a State X corporation which is engaged in Business A.
200116023(PDF, 11K)	4/20/2001
Request for a ruling whether PH is eligible for a credit or refund under § 6416 of the Internal Revenue Code of the excise tax it pays on gasoline under the cInternal Revenue Codeumstances described below. PH is a position holder with respect to gasoline in a terminal.
200116022(PDF, 5.7K)	4/20/2001
Requesting relief under � 1362(b)(5) of the Internal Revenue Code. X began doing business under State law on D1.
200116021(PDF, 6.1K)	4/20/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. Facts X was incorporated on Date 1.
200116020(PDF, 6.3K)	4/20/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date 1.
200116019(PDF, 6.2K)	4/20/2001
Requests relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1. 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.
200116018(PDF, 9.1K)	4/20/2001
Requesting an extension of time pursuant to � 301.9100-3 of the Procedure and Administration Regulations to file an election for amortization under � 169 of the Internal Revenue Code.
200116017(PDF, 15K)	4/20/2001
The District was formed by City pursuant to the Act, as amended in the year X. State enacted Act for the purpose of encouraging certain cities whose tax rates are near their limit to provide needed services in specific geographic areas within municipalities through the formation of assessment-based neighborhood districts.
200116016(PDF, 30K)	4/20/2001
Requesting rulings under §§ 61, 643, 1001, 1015, 1223, 2501, and 2601 of the Internal Revenue Code. Grantor executed a trust agreement creating an irrevocable inter vivos trust, Trust, on Date 1 for the benefit of Grantor's daughter, A, and A's issue.
200116015(PDF, 4.6K)	4/20/2001
Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X first had assets and issued stock on D1 of Year 1.
200116014(PDF, 37K)	4/20/2001
Issue: Whether a payment made from the proceeds of a tax-exempt bond was used for the acquisition, construction, reconstruction, or improvement of land or property of a character subject to the allowance for depreciation within the meaning of � 144(a)(1).
200116013(PDF, 19K)	4/20/2001
Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as the common parent of the consolidated group of which Purchaser is a member) and Seller are requesting the 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 (the "Election").
200116012(PDF, 76K)	4/20/2001
Issue: Whether the financial benefit an issuer of tax-exempt bonds received, including payments from a bondholder, in connection with alterations the issuer made to the terms of such bonds results in a reissuance of the bonds.
200116011(PDF, 5.6K)	4/20/2001
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.
200116010(PDF, 5.6K)	4/20/2001
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.
200116009(PDF, 14K)	4/20/2001
Requesting a ruling that the income of the Corporation will be excludable from gross income under � 115 of the Internal Revenue Code.
200116008(PDF, 46K)	4/20/2001
Issue: Whether Taxpayer may deduct any portion of the settlement payments made in Year 1 and Year 2 as interest expense.
200116007(PDF, 17K)	4/20/2001
You request rulings concerning the tax status of the Foundation and the estate tax consequences of the proposed transfer of the Land Estate from the Trust to the Foundation under § 501(c)(3) and § 2055(a)(2) of the Internal Revenue Code.
200116006(PDF, 21K)	4/20/2001
Requested rulings under §§ 2207A, 2519, and 2702 of the Internal Revenue Code. On a, Grantor executed an Amended and Restated Trust (the Trust).
200116005(PDF, 27K)	4/20/2001
Issue: Whether Entity Y's cancellation of Partnership X's debt service obligation of $d was received by Partnership X as a contribution to capital from partner A under § 721 of the Internal Revenue Code, or as taxable damages from Entity Y under § 61.
200116004(PDF, 26K)	4/20/2001
Request on behalf of the City for a ruling that the interest on the Bonds will be excluded from gross income under § 103 of the Internal Revenue Code. This letter ruling was submitted as a letter ruling subject to review under the declaratory judgment provisions of § 7478.
200116003(PDF, 19K)	4/20/2001
An extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser and Sellers are requesting the extension of time to file a "section 338(h)(10) election" under § 338(h)(10) of the Internal Revenue Code and § 1.338(h)(10)-1(d) of the Income Tax Regulations with respect to Purchaser's Date A acquisition of the stock of Target (the "Election").
200116002(PDF, 19K)	4/20/2001
Issue: Whether Shareholder A's receipt of Newco preferred stock, which contains a liquidation preference effective upon Newco's mandatory liquidation on Date L, is a taxable distribution of stock under § 305(b) and/or § 305(c) of the Internal Revenue Code?
200116001(PDF, 21K)	4/20/2001
The two issues are: (1) Whether the Service can establish an enforceable lien to secure the additional estate tax under � 2057 for personal property qualifying for the deduction under � 2057; and (2) Whether an estate electing the deduction under � 2057 can designate as security for the lien only those QFOBIs necessary to equal the amount of the additional estate tax payable in the event of a recapture.
200115044(PDF, 53K)	4/1/2001
We are responding to a request for a ruling concerning whether an amendment made to your organizing document will adversely affect your status as an organization described in � 501(c)(3) of the Internal Revenue Code. In addition, you are requesting a ruling that you can reasonably be expected to satisfy the requirements of � 507(b)(l)(B) of the Code during the 60-month period beginning on January 1, 2001.
200115043(PDF, 26K)	3/31/2001
This letter is in reply to your request dated July 10, 2000, for a private letter ruling concerning the federal income tax treatment. under � 414(h)(2) of the Internal Revenue Code of certain contributions to Plan X.
200115042(PDF, 28K)	3/30/2001
Issues: (1) whether the establishment, adoption, and operation of Plan E causes Pension Trust A to lose its tax-qualification or tax-exemption and (2) whether the method of funding of Pension Trust E jeopardizes the tax-exempt status of Pension Trust A.
200115041(PDF, 25K)	3/29/2001
This is in reference to your letter of November 2, 2000, requesting advance approval of your grant procedures under � 4945(g) of the Internal Revenue Code.
200115040(PDF, 70K)	3/28/2001
This is in response to your letter dated December 20, 1999, as supplemented by correspondence dated October 19 and December 6, 2000, in which you requested a ruling, on behalf participants in the above-named Plan, under � 72 and 402 of the Internal Revenue Code, and under certain provisions of the Technical and Miscellaneous Revenue Act of 1988 ("TAMRA"), Pub. L. 100-647, 1988-3 C.B. 1.
200115039(PDF, 69K)	3/27/2001
This is in response to your request dated xxxxx xx, 1999, as amended and supplemented by your letters dated xXxXx xx, 2000, xXxXx xx, 2000, and xxxxx xx, 2000, for a ruling that Taxpayer A should treat each automatic payment made pursuant to a systematic withdrawal program adopted with respect to certain deferred variable annuity contracts as part of a series of substantially equal periodic payments within the meaning of � 72(t) (2) of the Internal Revenue Code.
200115038(PDF, 61K)	3/26/2001
This is in reply to your rulings request of March 27, 2000, on Ts proposed transfer of all of its assets to C pursuant to � 507(b)(2) of the Internal Revenue Code.
200115037(PDF, 18K)	4/14/2001
Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as common parent of the consolidated group of which Purchaser was a member) and Seller are requesting an extension to file a "§ 338(h)(10) election" under §§ 338(g) and 338(h)(10).
200115036(PDF, 10K)	4/14/2001
Requesting a ruling under � 162(m) of the Internal Revenue Code. Specifically a ruling is requested that the deduction limitation of � 162(m) of the Code does not apply to Company A and its affiliates.
200115035(PDF, 12K)	4/14/2001
Subject: Request For Proof And Validation Of Assessment Internal Revenue Code §§ 6203 And 6331(J)(2)(A). The taxpayer told the revenue officer that, before collection can be made, the revenue officer "must furnish the taxpayer with the original assessment documents and copies of... required notices."
200115034(PDF, 12K)	4/14/2001
Subject: Tax Issues for Bosnian Refugees Immigrating to the United States. Requesting assistance on moving expense deductions for immigrants moving to the United States.
200115033(PDF, 12K)	4/14/2001
Subject: Internal Revenue Code § 62(c) - Louisiana School Bus Driver - Reimbursements for Bus Operating Expenses
200115032(PDF, 15K)	4/14/2001
Issue: Whether an individual may deduct a fee charged by a credit card company for using a credit card to pay the individual's personal income taxes due.
200115031(PDF, 29K)	4/14/2001
Subject: Review of Advisory Opinion--Offers in Compromise, Signature Authority for Power of Attorney
200115030(PDF, 20K)	4/14/2001
Pursuant to the plan, Acquiring and Target propose the following transaction (the "Reorganization"): (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. No fractional shares will be issued, due to the expense and inconvenience of issuing and transferring fractional shares.
200115029(PDF, 5.7K)	4/14/2001
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 one shareholder, Shareholder.
200115028(PDF, 17K)	4/14/2001
Requesting rulings on behalf of Fund 1, Fund 2, and Fund 3 (collectively, the "Funds") concerning the "look-through rule" of § 1.817-5(f) of the Income Tax Regulations for satisfying the diversification requirements of § 817(h) of the Internal Revenue Code.
200115027(PDF, 10K)	4/14/2001
Request for rulings on the federal income tax consequences of a proposed transaction. The facts presented indicate that MHC is a federally chartered mutual holding company using the accrual method of accounting.
200115026(PDF, 17K)	4/14/2001
Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Purchaser 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, with respect to Purchaser's acquisition of the stock of Target on Date B.
200115025(PDF, 8.1K)	4/14/2001
Requests an extension of time under Treasury Regulation § 301.9100-3 to file, for the tax year ended on Date B, the annual certification described in § 1.1503-2(g)(2)(vi)(B) with respect to the dual consolidated loss incurred in the tax year ended on Date A.
200115024(PDF, 8.0K)	4/14/2001
Requesting a ruling that A's surrender of his U.S. Alien Registration Card (Green Card) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code.
200115023(PDF, 9.9K)	4/14/2001
Requesting a private letter ruling that a positive adjustment required by � 481(a) of the Internal Revenue Code ("481 adjustment") will not be taken into account to determine whether X meets the gross income tests of � 856(c)(2) and (3) of the Code. X is a corporation. It owns 88% of the interests in P, a partnership that owns cold storage warehouses.
200115022(PDF, 12K)	4/14/2001
Requesting rulings, under 1362(f) of the Internal Revenue Code. According to the information submitted X was incorporated, in State, on Date (1) X filed a Form 2553, Election by a Small Business Corporation, to elect to be classified as an S corporation under � 1361, effective Date 2.
200115021(PDF, 4.7K)	4/14/2001
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.
200115020(PDF, 17K)	4/14/2001
Requesting relief under § 1362(f) of the Internal Revenue Code. You have represented that the facts are as follows. X is a corporation which made an S corporation election effective D1.
200115019(PDF, 33K)	4/14/2001
Issue: Whether the Internal Revenue Service can use an escrow demand under California state law to request payment of surplus proceeds from a trustee after a foreclosure sale, or whether the Service must use a Notice of Levy.
200115018(PDF, 4.9K)	4/14/2001
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.
200115017(PDF, 5.7K)	4/14/2001
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 one shareholder, Shareholder. It is represented that Company has intended to be an S corporation since a.
200115016(PDF, 17K)	4/14/2001
Request for rulings on certain federal income tax consequences of a proposed transaction. The plan consists of the following steps (the "Transaction"): (i) Target will transfer all of its assets and liabilities to Acquiring solely in exchange for newly issued Acquiring voting common and voting preferred stock (the "Transfer").
200115015(PDF, 33K)	4/14/2001
Issue: The sole issue set forth in your Field Service Advice (FSA) request is whether the Taxpayer is entitled to a deduction for original issue discount (OID) in the amount claimed ($P) in its taxable Year C.
200115014(PDF, 55K)	4/14/2001
Requesting rulings on behalf of Taxpayer, concerning the federal income tax treatment of certain disability benefits paid pursuant to Statutes A through D as amended by the Act.
200115013(PDF, 7.2K)	4/14/2001
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 D2.
200115012(PDF, 7.1K)	4/14/2001
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 D2.
200115011(PDF, 5.3K)	4/14/2001
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 president, chief executive officer, and sole shareholder of X, represents that X was intended to be an S corporation from its inception.
200115010(PDF, 20K)	4/14/2001
Requesting rulings under § 368(a)(1)(C) of the Internal Revenue Code (the "Code") with respect to a proposed transaction. Acquiring is a closed-end non-diversified management investment company organized under the laws of State X and registered under the Investment Company Act of 1940 (the "1940 Act").
200115009(PDF, 20K)	4/14/2001
Subject: Whether an officer of a corporation, representing the corporation pro se at trial in the Tax Court, may also testify at trial.
200115008(PDF, 12K)	4/14/2001
Requesting an extension of time under §§ 301.9100-1 through -3 of the Procedure and Administration Regulations to file an election. Parent is requesting an extension of time to file a statement of allowed loss under § 1.1502-20(c)(3) of the Income Tax Regulations (the "Election"), with respect to the sale of its stock in Subsidiary during its taxable year ending on Date 1.
200115007(PDF, 11K)	4/14/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date (1) The sole shareholder of X desired that X elect S corporation treatment effective on Date 1, but the election to be treated as an S corporation was not timely filed.
200115006(PDF, 12K)	4/14/2001
For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer, as one of the owners of the Plant, has a interest as a tenant in common.
200115005(PDF, 9.8K)	4/14/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1. 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.
200115004(PDF, 5.9K)	4/14/2001
Requesting relief under § 1362(b)(5) of the Internal Revenue Code. 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.
200115003(PDF, 89K)	4/14/2001
Issues: (1) Is the substance of the series of transactions involving the Property a sale of part of the Property or an economic sham? (2) Is the substance of the series of transactions involving the Property a financing arrangement?
200115002(PDF, 70K)	4/14/2001
Issues: I. What is the National Office position for the deduction of "losses incurred" with regard to the standards and procedures reflected in Treasury Regulation § 1.832-4 and Rev. Proc. 75- 56, 1975-2 C.B. 596? (1) Do the rules set out in Treas. Reg. § 1.832-4(a)(5)1 and 1.832-4(b) reflect different standards for determining the amount of a property and casualty (P&C) insurance company's allowable loss reserve and if so, what are the reasons for those different standards? (2) What is the meaning of the phrase "must represent actual unpaid losses as nearly as its is possible to ascertain them," as reflected in Treas. Reg. § 1.832-4(a)(5)? (3) What does the term "fair" mean in the "fair and reasonable" standard? (4) What is the meaning of the phrase "will be required to pay," as reflected in Treas. Reg. § 1.832-4(b)? (5) What is the appropriate standard of proof in cases regarding adjustments to unpaid losses? (6) Does Rev. Proc. 75-56 prescribe a testing methodology that the Service must utilize to determine whether the reserves that the taxpayer established were fair and reasonable? (7) Does Rev. Proc. 75-56 require the Service to hold that loss reserves for a particular year are fair and reasonable if subsequent actual loss payments plus remaining reserves for that year exceed the original reserves? II. Are contingent or anticipated asbestos and environmental (A&E) losses allowable for federal income tax purposes? III. Whether the change in Year 5 from a non-actuarial to an actuarial calculation of unpaid A&E losses constitutes a change in method of accounting?
200115001(PDF, 17K)	4/14/2001
The Prior Letter Ruling concerned a proposed split-off transaction (referred to as the "Split-off Transaction" in the Prior Letter Ruling; hereinafter, the "Proposed Split-off"). The Proposed Split-off has not, as yet, been consummated. This supplemental ruling addresses the effect of a proposed merger of Target with and into Parent (the "Proposed Merger") on the Prior Letter Ruling.

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2001 Chief Counsel'sWritten Determinations

2001 Chief Counsel's
Written Determinations