The following list presents documents prepared by Field attorneys in the Office of Chief Counsel that are reviewed by an Associate Office, and subsequently issued to field or service center campus employees of the Internal Revenue Service. NOTE: These items cannot be used or cited as precedent 20204201F PDF § 1.704-3(a)(10)(i) anti-abuse rule 20202501F PDF NOL Carryforward Audit in Taxable Year 20200801F PDF Statute of Limitations for IRC § 4980H 20193001F PDF Consent to Extend Time to Assess Tax for Tax Years 20184201F PDF I.R.C. § 1311 20183701F PDF Request for Advisory Opinion 20182502F PDF Commitment Fees 20182501F PDFAllocation of DPGR and non-DPGR 20182101F PDF Review of Proposed Notice of Deficiency 20181701F PDF Anti-Churning Rules 20181601F PDF AMT Preference Item- IDC and Hedging Income 20181201F PDF I.R.C. § 54E 20180601F PDFSection 481(a) Issue 20180101F PDF Section 1.451-4 20175101F PDF Sec. 597 Issue 20174901F PDF Subject: All-Events Test Reductions 20174602F PDF I.R.C.§ 143 (g) 20174601F PDF Mortgage Bonds Section I.R.C. .§ 143 20174501F PDF Mortgage bonds 20174201F PDF Section 199 Software Claim 20172901F PDF Deductibility of unamortized debt issuance costs 20172801F PDF Assessing tax on gift not reported on Forms 709 20172501F PDF Identification of Taxpayer on Form 872 20171801F PDF Request for Transfer of Deposits 20171601F PDF Qualified Research Expenses 20171202F PDF Employee Discount Under Section 132 20171201F PDF Section 530 20170501F PDF Notice of Proposed Adjustment (NOPA) Review 20165301F PDF Section 833(c)(3) 20165101F PDF Section 807(f) 20164101F PDF Section 199 Domestic Production Activities Deduction 20164001F PDF Short-Term Capital Gains and Taxation of Regulated Investment Companies 20163701F PDF Break Fee 20163602F PDF Notices of Proposed Adjustment 20163601F PDF Minimum Tax Credit 20163501F PDF Geological and Geophysical Expenditures 20162901F PDF TEFRA 20161801F PDF Tax Matters Partner 20161401F PDF Calculation of Percentage Depletion 20161102F PDF Agricultural Chemical Security Credit 20161101F PDF Section 45 Refined Coal Credit 20154703F PDF Hedging Transaction 20154702F PDF Payment to Foreign Government 20154701F PDF Determination of Amount of and Recognition of Gain or Loss 20154601F PDF I.R.C. § 168 – Loss on Disposition of Building Structural Components 20154502F PDF Legal Fees Incurred to Create an FDA-Approved ANDA 20154501F PDF Determination of Reasonable Compensation for purposes of I.R.C sections 162 & 174 20153901F PDF Form 2848 review – Part II 20153601F PDF Question Regarding Multiple Buy-ins to Poker Tournament 20153501F PDF Bad Debts 20152201F PDF I.R.C. Section 6501(c)(9) Exception to Statute of Limitations 20153301F PDF Intercompany Referral Fees 20153101F PDF Treatment of Expenses Incurred on Behalf of Joint Venture 20153001F PDF Reporting and Payment of LIFO Recapture 20152302F PDF Failure to Honor Levy 20152301F PDF Service Reliance on a Consent 20152104F PDF Disposition under I.R.C. Section 367(d) 20152103F PDF Deductibility of Payment Under FDA Consent Decree 20152102F PDF Payments for Negative Easements 20152101F PDF Form 941, Form 944, and the Period of Limitations 20151704F PDF Application of Sections 1.263(a)-4 and 5 to Consent Payment 20151703F PDF Claim for Refund: Federal Telephone Excise Tax 20151702F PDF Section 382 20151701F PDF I.R.C. §§ 382 and 482 20151601F PDF Railroad Track Maintenance Credit Computation 20151201F PDF Exchangeable Debentures 20151002F PDF Requirement to File Information Returns Under IRC section 6041 and/or 6045 20151001F PDF Alternative Fuel Mixture Credit 20150801F PDF PURPIM under IRC section 1388(f) 20150701F PDF Deductibility of Unreimbursed Expenses 20150601F PDF Review of FASIT Transaction 20150301F PDF Application of SRLY Provisions 20145102F PDFCostless Collar Transaction 20145101F PDF Capitalization of Royalties – 263A COGS 20145001F PDF Application of TEFRA to Employment Tax Examinations 20144801F PDF Characterization of Amounts Received on the Sale of I.R.C. Section 166 Impaired Real Estate Mortgage Investment Conduit Regular Interests 20144702F PDF Inclusion of Funding Agreement Interest in Policy Interest 20144701F PDF Acquiring Corporation’s Use of Target’s Pre-Acquisition Qualified Research Expenses 20144601F PDF Extended Five-Year Carryback of Net Operating Losses from Operations 20144201F PDF Alternative Tax Net Operating Loss Absorption Rules 20141001F PDF Deductibility of Payment of Underwriting Costs 20141002F PDF Section 172(f)(1) Rebuttal 20140202F PDF Whether Taxpayer is Entitled to Bonus Depreciation 20140201F PDF Treatment of Premium Stabilization Reserves 20134901F PDF Gain or loss from the sale of securities reported on Forms 1120-SF 20134801F PDF Deferral of Income Recognition for Contracts for the Sale of Goods 20133901F PDF Amortization of Player Contracts 20133702F PDF Section 6404(g) 20133701F PDF Section 833(b) Special Deduction 20133501F PDF Reporting Requirements for Attorney’s Fee Paid 20133303F PDF Application of Section 6702 Penalty to Taxpayer 20133302F PDF Section 199 Claim for Photo Processing Activities 20133301F PDF Validity of Closing Agreement 20133101F PDF Whether taxpayer is entitled to a deduction for abandonment losses 20132801F PDF Deduction for Indemnification of Liability 20132702F PDF Whether sales from selling/licensing software are foreign base company income 20132701F PDF Deduction Against Nonpatronage - Sourced Income 20132101F PDF Whether holdings is a continuation of Taxpayer 20131902F PDF Treasury Regulation 1.246-5(c)(6) Use of related persons or pass-through entities 20131901F PDF Character of Gain on Sale of Merchant Contracts 20131802F PDF Aggregation of Patronage and Non-Patronage Sourced Activities 20131801F PDF Worker Classification Issue 20131701F PDF SPV Financing Transaction 20131601F PDF Majority Shareholder 20131201F PDF Amortization of Patents 20131102F PDF Treatment of Voluntary Separation Payments under IRC § 41 20131101F PDF Authority to Sign Form 870-LT 20131001F PDF Capitalization of Litigation Fees Incurred 20130501F PDF I.R.C. § 162 20130101F PDF Gross Income and Grants to Railroads 20125202F PDF Foreign Tax Credit 20125201F PDF Analysis of Negligence Penalty and Reasonable Basis under IRC § 6662 20124801F PDF Like-Kind Exchange 20124701F PDF Whether the Mitigation Provisions contained in IRC Sections 1311 to 1314 Apply 20124603F PDF Whether Taxpayer is entitled to a claimed abandonment loss 20124602F PDF Form 1099 Requirements for Claims 20124601F PDF Transitory Corporations and I.R.C. section 351 20124402F PDF Form 1099 Requirements for Claims 20124401F PDF Capitalization of minimum royalties under section 263A 20124201F PDF Responses to Attorney Letter 20124103F PDF Income from Discharge of Indebtedness 20124102F PDF Request for Mitigation 20124101F PDF Refund with respect to the carryback of CNOL 20124002F PDF Rehabilitation Tax Credit Issue 20124001F PDF Comparability Adjustments under § 482 20123905F PDF Refund Claim 20123904F PDF Authority to Sign Form 870-LT 20123903F PDF Rebuttal to Taxpayer’s Protest 20123902F PDF Acceptance of 5 year carryback election 20123901F PDF Application of the Attorney-Client Privilege to Corporate Minutes 20123801F PDF Taxpayers Amended Return 20123401F PDF Application of Judicial Doctrines to Monetization Transaction 20123201F PDF Application of Section 263A to OREO property 20123002F PDF Bad Debt Deduction 20123001F PDF Taxation of Commercialization Agreement 20121701F PDF Gain Recognition 20121602F PDF Deduction for Chargeback Reimbursement Accrued Expense 20121601F PDF Research Credit -- Excluded Activities Funded Research 20121501F PDF Application of Mitigation Rules 20121401F PDF Research Credit – Excluded Activities Funded Research 20121202F PDF Holding Period Requirement for Dividends-Received Deduction 20121201F PDF Holding Period Requirement for Dividends-Received Deduction 20115101F PDF Temporary Taking of Two Properties Attributable to an Involuntary Conversion 20115001F PDF Non-deductibility of Certain Corporate Costs 20114901F PDF Attorney Fees Incurred to Defend Against Patent Infringement Claims and to Investigate Patents 20114704F PDF Conversion of Penalty Portion of Settlement Allocation in Class Action Lawsuit to Wages 20114703F PDF Cost Recovery of Capitalized Attorney Fees Incurred to Defend Against Patent Infringement Claims and to Investigate Patents 20114702F PDF LIFO Conformity Violation 20114701F PDF Examination of Previously examined Year in Connection with Net Operating Loss Carryback 20113901F PDF Qualifying Small Power Production Facility 20113802F PDF Income Recognition from Sales of Gift Checks by a Membership Special Entity 20113801F PDF Contribution of Inventory Approaching “best by” Date 20112701F PDF Bank Enterprise Award payment received from the U.S. Department of the Treasury Community Development Financial Institutions Fund 20111701F PDF Tax Matters Partner's Authority to Sign a Form 872-P 20111101F PDF Deductibility of Purportedly Worthless Goodwill 20105101F PDF Retroactive Re-classification of Purchases into PURPIMS 20105001F PDF Foreign Tax Credit 20103901F PDF Graduate Level Tuition Waivers as Taxable Fringe Benefits 20103101F PDF Patronage Dividend Deduction 20103002F PDF Income Tax Adjustment for Certain Payments or Discounts made in Violation of the Anti-Kickback Act, 41 U.S.C. sections 51-58 20103001F PDF TEFRA Partnership Issues 20102901F PDF Request for Legal Advice on Procedures when Dealing with Frivolous Business Returns 20102602F PDF Application of Uniform Capitalization Rules of Section 263A to Ending Physical Grain Inventory Held for Resale 20102601F PDF Wrongful Levy 20101502F PDF I.R.C. Section 833(b) Special Deduction 20101501F PDF Housing Authority Mutual Help Homeownership Opportunity Program 20100902F PDF I.R.C. Section 482 Acquisition Buy-in 20100901F PDF Use of Gift Card Disregarded Entity 20100502F PDF Use of Tax Book Value to Establish Fair Market Value of Assets 20100501F PDF Effect of Closing Agreement on Taxpayer's LIFO Definition of an Item 20100301F PDF Tax Treatment of Post-Spinoff Payments 20095001F PDF Small Ethanol Producer Credit – Qualification as an eligible small ethanol producer 20094302F PDF Execution of Form 872-P 20094301F PDF Deductibility of Statutory Stock Options under Sec. 174 20093801F PDF Separate Gift Card Company Servicing Affiliated Restaurants 20093701F PDF Collection of Employment Taxes from the Property of the Individual Single Member of a Disregarded Entity 20092103F PDF Worker Classification of Review Board Members 20092102F PDF Seizure and Sale of Right to Renew Season Tickets 20092101F PDF Advice Concerning I.R.C. Section 845(b) 20090801F PDF Deductibility of Interest by U.S. Insurance Subsidiary 20085201F PDF MEGA Tax Credit 20084602F PDF Application of Proceeds Obtained from sale of Seized Property 20084601F PDF Assessment and Collection of the Addition to Tax under I.R.C. Sec. 6651 for failing to Pay the Tax Agreed Upon in the Closing Agreement 20084304F PDF Deductibility of Anti-trust Settlement Payments 20084204F PDF Erroneous Refund of Withheld Social Security Tax 20084104F PDF Accrual of Telecast License Fees 20082804F PDF Securing Extensions of the Statute of Limitations from S Corporation Shareholders that are Grantor Trusts 20082803F PDF Involuntary Conversions of Broadcasting Equipment 20082802F PDF Relief under I.R.C. Section 1341 for Payments made to Settle Qui Tam (“Whistleblower”) Lawsuits 20082801F PDF Recognition of Gift Card Sale Proceeds 20080101F PDF Taxation of Purported Contingent Payment Sale 20075201F PDF Taxation of License Agreement 20075001F PDF Request for Advice Regarding Allowance of Application for Tentative Refund Based On Claim of Right Adjustment Pursuant to I.R.C. section 1341 20074901F PDF Gain Recognition Agreements and Reasonable Cause Exceptions under Sec. 367 20074401F PDF Newspaper Mastheads, Advertiser Accounts, and Subscriber Accounts under Section 1031 20073802F PDF Advice on the Time for Making the I.R.C. Section 847 Election 20073801F PDF Theft Loss Advisory 20073301F PDF Deductibility of a clawback payment claimed as a royalty payment 20072502F PDF Application of Rev. Rul. 89-96 to subject Retroactive Reinsurance Transaction 20072501F PDF Refund of Sec. 847 Special Estimated Tax Payments (SETP) Paid in Prior Years 20072201F PDF Deductibility of 2 1/2% Additional Tax under California Rev. and Tax. Code Sec. 17085 20072101F PDF Television Network Affiliation Agreement Issues 20071801F PDF Tax Treatment of Various Services Related to Environmental Remediation Liabilities 20071702F PDF I.R.C. Section 41(d)(4): Qualified Research; Activities after the beginning of commercial production 20071701F PDF Consent to Extend Statute of Limitations on Assessment; Execution of Waiver of Restrictions on Assessment 20071101F PDF Valuation of Excess Parts Inventory 20070801F PDF Issues relating to Agreement to Special Lien 20070601F PDF Application of Rev. Rul. 2001-8 to Rebates 20070401F PDF Temporary Markdowns Under the Lower-of-Cost-or-Market Inventory Method 20065101F PDF Amended return with tax increase and NOL carryback 20064602F PDF Form 5471 Filing and Penalty for Failure to File 20064601F PDF Worthlessness of partnership interests in and loans to 20064401F PDF Redemption of Stock 20064301F PDF Calculation of LIFO Index (I.R.C. Sec. 472) 20062801F PDF Prepayment of Electricity Discounts under Amended Power Purchase Agreement 20062701F PDF Assertion of penalties for failure to file information returns with respect to certain foreign entities 20062201F PDF PORC Audit Issues 20061703F PDF Advice regarding substantial omission and listed transaction exceptions (I.R.C. Sec. 6501) 20061702F PDF Priority of estate tax lien 20061701F PDF Vacation and bonus pay employment tax accrual 20060902F PDF Collection After Assessment 20060901F PDF Taxability of Payments to Recipients Under a State Fund 20055203F PDF Deductibility of research and experimental expenditures under I.R.C. § 174 20055202F PDF Tax treatment of Continued Dumping and Subsidy Offset Act (CDSOA) subsidy 20055201F PDF Theft Loss Advisory 20052501F PDF Need for a new Form 8655 when EIN merges occur 20051802F PDF Treatment of Certain Losses 20051801F PDF Duplicated Loss 20051001F PDF Books and Records Income Allocation Method under I.R.C. § 863 20050203F PDF Whether the subject sale and acquisition of property qualifies for like-kind exchange treatment under I.R.C. §1031 20050202F PDF The effect of I.R.C. § 6213(f) on calculations of the last date to file a petition with the Tax Court upon dismissal or discharge from bankruptcy and the statute of limitations date for making an assessment of tax 20050201F PDF Advisory Opinion on Collection of Taxes 20044103F PDF Whether a manufacturer using the Inventory Price Index Computation inventory method may properly determine its gross profit margin (to convert its selected BLS indexes to cost price indexes) using data from a selected month rather than data from the entire year (UILC 472.09-00) 20044102F PDF Has a taxpayer engaged in a valid purchase of replacement property, as described in I.R.C. § 1033(a)(2)(A), for an involuntarily converted timber cutting contract with the U.S. Forest Service (UILC 1033.00-00) 20044101F PDF Is a pipeline that is part of a crude oil gathering system of like-kind, within the meaning of I.R.C. § 1031(a), to property for which it was exchanged (UILCs 1031.01-00 and 1031.02-00) 20043103F PDF Whether the permissible variation of the simplified resale method, set forth in Treas. Reg. § 1.263A-3(d)(3)(iii)(B), requires annual increases to the total cumulative amounts of storage and handling costs capitalized to existing LIFO layers (UILCs 263A.04-00, 472.08-00) 20043102F PDF Compliance with Placed-in-Service and Written Binding Contract Rules (UILC 9999.98-00) 20043101F PDF Failure to timely file annual certifications and waivers in connection with a gain recognition agreement (UILCs 367.03-14, 6038B.03-00) 20042903F PDF Mobile Machinery Exception to Definition of Highway Vehicle (UILC 4041.04-02) 20042902F PDF A challenge in state probate court of a final Tax Court decision which provides that a spouse is relieved from joint and several liability for income taxes (UILC 9999.98-00) 20042901F PDF The manner in which taxpayers recompute their federal tax liability following the carryback of a NOL that is not fully absorbed in the carryback year (UILC 172.00-00) 20042308F PDF Valuation of a greater-than-10-percent corporate partnership for purposes of apportioning a partner’s interest expense incurred outside of the partnership (UILC 861.09-00) 20042307F PDF A determination of whether or not the taxpayers were responsible for taxes and a civil penalty owed by their partnership 20042306F PDF Evaluation of taxpayers' compliance with placed-in-service and written binding contract requirements 20042305F PDF A determination of whether or not the transaction at issue gave rise to a currently taxable event under I.R.C. § 1259 and Rev. Rul. 2003-7 20042304F PDF The proper treatment of a sales discount in the context described therein 20042303F PDF Issues relating to the ownership of a depreciable interest (UILC 167.15-00) and the limitations on casualty and theft losses of individuals (UILC 165.04-00) 20042302F PDF Timing of loss for expenditures to provide payphone access to disabled individuals 20042301F PDF Extraterritorial income exclusion 20040303F PDF Computation of tax where taxpayer makes payment to settle pending lawsuits (I.R.C. § 1341) 20040302F PDF Treatment of investigatory expenses incurred in starting up a business (I.R.C. § 195) 20040301F PDF Treatment of advances as a preferred class of equity in the context of a complete liquidation of a subsidiary (I.R.C. § 332) 20032902F PDF Deductibility of compensation expenses attributable to stock options awarded to expatriate employees; I.R.C. § 83 and 162 20032901F PDF Allocation of the I.R.C. § 6707 penalty among co-promoters 20032601F PDF I.R.C. § 6694 Penalty; U.I.L. Nos. 6694.01-00 and 6694.02-00 20032401F PDF Foreign Tax Credit Implications in Ownership-FSC Transactions 20031901F PDF TEFRA statute of limitations for assessments of tax with respect to partnership adjustments 20031501F PDF Deductibility of Insurance Premiums; Premiums as Constructive Dividends to Insured/Other Shareholders; Deferred Compensation or Dividends/Sale of Stock/Installment Redemption
