These documents are prepared by field attorneys in the Office of Chief Counsel, 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.
2007
- 20075201F — Taxation of License Agreement PDF
- 20075001F — Request for Advice Regarding Allowance of Application for Tentative Refund Based On Claim of Right Adjustment Pursuant to I.R.C. section 1341 PDF
- 20074901F — Gain Recognition Agreements and Reasonable Cause Exceptions under Sec. 367 PDF
- 20074401F — Newspaper Mastheads — Advertiser Accounts — and Subscriber Accounts under Section 1031 PDF
- 20073802F — Advice on the Time for Making the I.R.C. Section 847 Election PDF
- 20073801F — Theft Loss Advisory PDF
- 20073301F — Deductibility of a clawback payment claimed as a royalty payment PDF
- 20072502F — Application of Rev. Rul. 89-96 to subject Retroactive Reinsurance Transaction PDF
- 20072501F — Refund of Sec. 847 Special Estimated Tax Payments (SETP) Paid in Prior Years PDF
- 20072201F — Deductibility of 2 1/2% Additional Tax under California Rev. and Tax. Code Sec. 17085 PDF
- 20072101F — Television Network Affiliation Agreement Issues PDF
- 20071801F — Tax Treatment of Various Services Related to Environmental Remediation Liabilities PDF
- 20071702F — I.R.C. Section 41(d)(4): Qualified Research; Activities after the beginning of commercial production PDF
- 20071701F — Consent to Extend Statute of Limitations on Assessment; Execution of Waiver of Restrictions on Assessment PDF
- 20071101F — Valuation of Excess Parts Inventory PDF
- 20070801F — Issues relating to Agreement to Special Lien PDF
- 20070601F — Application of Rev. Rul. 2001-8 to Rebates PDF
- 20070401F — Temporary Markdowns Under the Lower-of-Cost-or-Market Inventory Method PDF
2006
- 20065101F — Amended return with tax increase and NOL carryback PDF
- 20064602F — Form 5471 Filing and Penalty for Failure to ob体育 PDF
- 20064601F — Worthlessness of partnership interests in and loans to PDF
- 20064401F — Redemption of Stock PDF
- 20064301F — Calculation of LIFO Index (I.R.C. Sec. 472) PDF
- 20062801F — Prepayment of Electricity Discounts under Amended Power Purchase Agreement PDF
- 20062701F — Assertion of penalties for failure to file information returns with respect to certain foreign entities PDF
- 20062201F — PORC Audit Issues PDF
- 20061703F — Advice regarding substantial omission and listed transaction exceptions (I.R.C. Sec. 6501) PDF
- 20061702F — Priority of estate tax lien PDF
- 20061701F — Vacation and bonus pay employment tax accrual PDF
- 20060902F — Collection After Assessment PDF
- 20060901F — Taxability of Payments to Recipients Under a State Fund PDF
2005
- 20055203F — Deductibility of research and experimental expenditures under I.R.C. § 174 PDF
- 20055202F — Tax treatment of Continued Dumping and Subsidy Offset Act (CDSOA) subsidy PDF
- 20055201F — Theft Loss Advisory PDF
- 20052501F — Need for a new Form 8655 when EIN merges occur PDF
- 20051802F — Treatment of Certain Losses PDF
- 20051801F — Duplicated Loss PDF
- 20051001F — Books and Records Income Allocation Method under I.R.C. § 863 PDF
- 20050203F — Whether the subject sale and acquisition of property qualifies for like-kind exchange treatment under I.R.C. §1031 PDF
- 20050202F — 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 PDF
- 20050201F — Advisory Opinion on Collection of Taxes PDF