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LET RULLetter Ruling (issued by US Internal Revenue Service)
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The letter ruling specifies how to treat the partnership, but it does not address how to treat the creditor-partner or the other departing partners.
In private letter ruling 9636003, the IRS said such vehicles remained passenger automobiles regardless of their use, and the company was denied a refund and credit for gasoline taxes.
The progression and continuing viability of the IRS's initial private letter ruling on rabbi trusts are illustrated by a series of subsequent rulings.
In a letter ruling, (33) nonreimbursable economic development grants made by a Native American tribal nation to eligible members were held to be excludible from income.
In private letter ruling 9604027, an individual named his daughter sole heir but beneficiary of his estate in his will built designated his estate as beneficiary of the IRA, Because his estate as the beneficiary, the IRS said that the entire IRA balance had to be distributed and taxed to his daughter in the year after his death.
In a private letter ruling dated October 21, 1969, however, the IRS held that the plan would not qualify as a reorganization under 368(a)(1)(B) unless ITT disposed of the Hartford stock it had purchased for cash in the previous year.
Letter Ruling (TAM) 9821001: In this ruling, the taxpayer indicated it was using the SPM on Form 3115, Application to Change Accounting Method.
A letter ruling generally is binding on an IRS district office for purposes of determining a taxpayer's liability.
Before taxpayers claim the full amount of private school tuition as a deduction, however, there are other requirements in Letter Ruling 200521003 that must be met:
The IRS said it was reviewing private letter ruling 9317037--the one cited in this article--due to concerns over potential constructive receipt in certain plan designs.
In a letter ruling, (44) several S shareholders that were QSSTs did not distribute their income currently, thus making them ineligible shareholders and terminating the S election.
In letter ruling 9133004, a technical advice, the finance subsidiary obtained funds from the foreign parent via a capital contribution and from proceeds derived from the sale of debentures.