In a ruling
, (61) two unrelated shareholders (A and B) each owned 50% of the stock of X Corp.
Rule 263.28 of the Board's Rules provides that the Board may exercise interlocutory review of an ALJ' s ruling
if the Board finds that:
The proposed ethics ruling
under Rule 201, "General Standards," and Rule 202, "Compliance With Standards," clarifies the application of Rules 201 and 202 to members who use a third-party service provider in providing professional services to clients, and makes clear the committee's position that the member is responsible for all work performed by the service provider.
James Dobson, founder of the sprawling religious broadcasting empire, Focus on the Family, issued a statement deploring the Pledge ruling
* The ruling
does not apply to unvested options at transfer.
Because scientific uncertainty attends so many rule makings, the ruling
leaves open the question of when the EPA may make what is essentially a policy determination versus when those determinations should be made by Congress.
One hopeful sign is the June 27, 1997, superior court ruling
in Chittenden Township School District v.
The other, even more controversial, was to propose a ruling
class consisting of 417 of those lineages, which collectively accounted for no less than 34.2 percent of Florence's population in 1480.
2003-43, (3) which grants S corporations, qualified subchapter S subsidiaries (QSubs), ESBTs and QSSTs a 24-month extension to file Form 2553, Election by a Small Business Corporation, Form 8869, Qualified Subchapter S Subsidiary Election, or a trust election, without obtaining a letter ruling
. It appears that the procedure is having its intended effect.
99-23 addresses only the applicability of section 195 to costs incurred in connection with a new trade or business unrelated to the taxpayer's existing business, many read the ruling
as establishing a general capitalization principle distinguishing between deductible investigatory costs and capitalizable acquisition costs.
Ethics interpretations and rulings
are promulgated by the executive committee of the professional ethics division to provide guidelines as to the scope and application of the rules but are not intended to limit such scope or application.
Judge DeMent's ruling
orders an end to a variety of unconstitutional activities.
Tax advisers must understand the weight (or deference) courts give to revenue rulings
when they determine a level of authority (e.g., reasonable basis, substantial authority, or more-likely-than-not) for a tax return position that implicates a revenue ruling
These representations, like the ruling
request itself, must be made under penalties of perjury.
In an interesting switch, both the taxpayer and the IRS said the lower court had decided Miller incorrectly, arguing that revenue ruling
76-511 (which was outstanding at the time) was on point and the lower court had not considered it.