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Section 144 - Small Issue Bond Defined: $10,000,000 Limit; Manufacturing Facility

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Small Issue Bond Defined:

PLR200116014
Whether a payment made from the proceeds of a tax-exempt bond was used for the acquisition, construction, reconstruction, or improvement of land or property of a character subject to the allowance for depreciation within the meaning of section 144(a)(1).

TAM199949035
Whether an Individual's purchase of land and a partnership interest from a related person within the 3-year period preceding the issue date of the Bonds, are capital expenditures under section 144(a)(4) of the Internal Revenue Code.

 


$10,000,000 Limit:

PLR200050034
This letter is in reply to a request for rulings that (1) an allocation of bond proceeds may be disregarded, and (2) certain expenditures are not capital expenditures within the meaning of section 144(a)(4)(A) of the Internal Revenue Code.

 


Manufacturing Facility:

PLR200234012 (05/07/2002)
This letter is in response to your request for a ruling that the Facility you plan to finance by the proceeds of the Bonds would be a "manufacturing facility" under section 144(a)(12)(C) of the Code.

TAM200122004
Whether specially equipped greenhouses and a cold storage building used for growing and storing plants are a manufacturing facility within the meaning of section 144(a)(12)(C) of the Internal Revenue Code?

TAM200025004
Whether the Facility, used for the purpose of curing cheese, is a manufacturing facility under section 144(a)(12)(C) of the Internal Revenue Code.

FSA200010018
Whether a facility used for the growing of plants is engaged in manufacturing within the meaning of section 144(a)(12)(C) of the Internal Revenue Code.

FSA200010012
Whether certain operations of a vegetable processing facility, which include the cleaning, cooking, freezing, and packaging of freshly harvested vegetables, constitute manufacturing within the meaning of section 144(a)(12)(C) of the Internal Revenue Code.

TAM199904034
Whether the proceeds of the Bonds were used to provide a "manufacturing facility" within the meaning of section 144(a)(12)(C) of the Internal Revenue Code.

Page Last Reviewed or Updated: 17-Apr-2014