Internal Revenue Cumulative Bulletin, Volum 1

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Department of the Treasury, Internal Revenue Service, 2003
 

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Innhold

Generally not to business associations or groups
14
Not on frivolous issues
15
UNDER WHAT CIRCUMSTANCES DO DIRECTORS ISSUE DETERMINATION LETTERS?
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Requests concerning income estate or gift tax returns
17
Ordinarily not on which of two entities is the common law employer
18
3 Analysis of material facts
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6 Statement regarding interpretation of a substantive provisions of an income or estate tax treaty
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10 Statement identifying pending legislation
21
12 Signature by taxpayer or authorized representative
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14 Power of attorney and declaration of representative
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16 Number of copies of request to be submitted
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2 To designate recipient of original or copy of letter ruling or determination letter
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4 To request expedited handling
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5 To receive any document related to the letter ruling request by facsimile transmission fax
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2 Requests for determination letters
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When to attach letter ruling to return
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Compliance with Treasury Department Circular No 230
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Safe harbor revenue procedures
34
Automatic change revenue procedures
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HOW DOES THE NATIONAL OFFICE HANDLE LETTER RULING REQUESTS?
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Is not bound by informal opinion expressed
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Near the completion of the ruling process advises the taxpayer of conclusions and if the Service will rule adversely offers the taxpayer the opportunit...
40
Sends a copy of the letter ruling to appropriate Service official
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May offer additional conferences
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May schedule a conference to be held by telephone
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Will not apply to another taxpayer
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Not otherwise generally revoked or modified retroactively
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Generally not retroactively revoked or modified if related to sale or lease subject to excise tax
46
WHAT SIGNIFICANT CHANGES HAVE BEEN MADE TO REV PROC 20021?
55
APPENDIX BSAMPLE FORMAT FOR A LETTER RULING REQUEST
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APPENDIX DLIST OF SMALL BUSINESSSELFEMPLOYED DIVISION SBSE COMPLIANCE AREA
74
Rev Proc 20032
79
HOW ARE PRESUBMISSION CONFERENCES SCHEDULED?
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Request for a presubmission conference must be submitted in writing by the field or area office
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National office may provide views
97
Conference may not be taped
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Additional information submitted after the conference
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Normally conducted by telephone
100
Detemiines whether request has been properly made
101
Advises the field or area office if tentative conclusion is changed
102
Requests taxpayer to send additional information to the national office and a copy to the director or area direc tor appeals
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Routes replies to appropriate office
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Discussion with the taxpayer
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When no copy is given to the taxpayer
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HOW MAY RETROACTIVE EFFECT BE LIMITED?
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WHAT IS THE This revenue procedure explains when and how the Associate Chief Counsel Corpo
113
Purpose of presubmission conference
171
WHAT MUST BE INCLUDED IN THE REQUEST FOR TECHNICAL ADVICE?
172
General provisions of 6104 and 6110 of the lntemal Revenue Code
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Number of copies of request to be submitted
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If the Service disagrees with the taxpayers statement of facts
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Criminal or civil fraud cases
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HOW ARE REQUESTS FOR TECHNICAL ADVICE WITHDRAWN?
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Normally held within 21 days of contact with the taxpayer
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Service makes tentative recommendations
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Under limited circumstances may schedule a conference to be held by telephone
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Determines whether request has been properly made
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Advises the EP or E0 Examinations or the EP or E0 Determinations or the appeals office of final conclusions
182
Prepares reply in two parts
183
HOW DOES EP OR EO EXAMINATIONS OR EP OR EO DETERMINATIONS OR AN APPEALS OFFICE USE THE TECHNICAL ADVICE?
184
When no copy is given to the taxpayer
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HOW MAY RETROACTIVE EFFECT BE LIMITED?
186
Form of request to limit retroactivity technical advice that does not modify or revoke prior memorandum
187
employee plans exempt organizations and government enti
220
DEFINITIONS For purposes of this revenue procedure
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Sec 21
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