In a ruling
, (61) two unrelated shareholders (A and B) each owned 50% of the stock of X Corp.
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.
also enjoined all school-organized or officially sanctioned religious activities in classrooms or over the schools' public address systems, including vocal prayer and Bible reading.
In a highly technical ruling
earlier this year, the WTO distinguished exceptions to general tax rules from tax exemptions that result from a general rule of taxation -- the former constituting a subsidy; the latter not.
In another ruling
, (6) the corporation filed both Form SS-4, Application for Employer Identification Number, indicating it planned to be an S corporation, and Form 1120S, U.
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.
On December 7 the IRS issued revenue ruling
90-105, which changed the deductibility of 401(k) contributions made after yearend.
Some courts, including the Tax Court, historically have given no weight to revenue rulings
, on the theory a ruling
is merely an interpretation of the law asserted by one of the parties in litigation.
In 1953, the IRS issued revenue ruling
53-190 (1953-2 CB 303), which allowed a deduction for daily transportation expenses between a taxpayer's residence and a temporary work location outside the taxpayer's metropolitan area if the taxpayer has no specific regular place of business or employment.
2003-43, (1) 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
In its brief, TEI stated that the issue of the deference to be accorded an agency's interpretative ruling
"requires a careful balance and the answer properly depends on the extent of public involvement in the development of the agency rule.
A letter ruling
is a written statement issued by the IRS national office to a taxpayer or the taxpayer's authorized representative interpreting and applying the tax laws to a specific set of facts.
Other than Letter Ruling
199925044, no regulations or other guidance addressing the treatment of unbalanced straddles has been issued.
Demonstrating just how misleading it can be to selectively quote judicial opinions, the government artfully cites Correll in arguing that "an interpretive ruling
adopted by the Treasury under the Internal Revenue Code must be upheld as long as it represents a `reasonable' interpretation of the statute.