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IRC Section 61 - TAM

Technical Advice Memorandum - IRC Section 61

Issue TAM Number
Whether gross income was received when tribe funded trust for beneficiary.

TAM-200106007

10/20/2000

Whether Taxpayer has demonstrated that it acted reasonably and in good faith to achieve the dissolution of the state-chartered corporation and organization into a corporation described in section 17 of the IRA.

TAM-199901001

8/7/1998

Whether per capita payments made under Indian Gaming Regulatory Act are excludible from gross income. (Owner v. Grantor of the Trust)

TAM-9723007

2/13/1997

Whether per capita payments made under the Indian Gaming Regulatory Act are excludible from gross income.

TAM-9717007

1/13/1997

Whether Taxpayers' Indian-related income can appropriately be allocated between income that is directly derived from the lands and income that is derived from improvements and, if so, what method should be utilized in applying the allocation.

TAM-8349005

4/18/1983

Whether Indian related income can appropriately be allocated between income that is directly derived from the land, and income that is derived from improvements to the land, and if so, what is the proper allocation method.

TAM-8337004

4/13/1983

Whether, for federal income tax purposes, the Corporation, a federally chartered tribal corporation, is an entity separate and distinct from the Tribe, a recognized Indian tribe and, if it is, whether it is subject to federal income tax.

TAM-8111010

10/30/1980

Page Last Reviewed or Updated: 29-Jan-2014