Because the letter ruling
does not discuss the tax consequences to the creditor-partner, it is unclear whether Sec.
After the woman's death, the IRS, in private letter ruling
9634004, included the gifted property in the decedent's gross estate under IRC section 2038, because the power to make the gifts was not expressly authorized.
Another anti-takeover feature received approval in Letter Ruling
(7) See Chief Counsel Advice (CCA) 200021036 (5/26/00); and IRS Letter Ruling
In private letter ruling
9604027, the decedent should have named his daughter, not his estate, as the beneficiary so that she could receive the annual distributions after his death.
In March 1974, the IRS retroactively revoked the October 1969 letter ruling
on the grounds that the nature of the obligations and rights of the parties to the sale had been misrepresented.
(TAM) 200144003: In this ruling, the taxpayer was using another reasonable method or variation of the SRM by excluding in-transit inventory and in-transit purchasing costs to determine the storage and handling ratio.
For example, assume X and Y apply for and receive a private letter ruling
allowing them to enter into a tax-free reorganization to form a parent-subsidiary group.
Further, letter rulings
are not precedential and apply only to the specific facts presented in the request, although they do indicate the Service's thinking.
Although the IRS position in this area appears clear, the best insurance for a company concerned about the IRS's position on an individual plan is to apply for a private letter ruling
Late elections: Several years ago, in an attempt to reduce the number of letter rulings
in this area, the IRS issued Rev.
Observation: In this letter ruling
, the IRS pierced the "equity wall" of a foreign finance subsidiary used for inbound financing.