Section 147 - Public Approval Requirements and Reasonable Economic Life
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Public Approval Requirements:
This letter is in response to a request on behalf of the Authority for a ruling that the acting governor of the State may be treated as the applicable elected representative for the purpose of satisfying the public approval requirement of §147(f) of the Internal Revenue Code.
This in response to a letter on behalf of the Issuer and Borrower requesting a private letter ruling that the use of Bond proceeds as described below will be an insubstantial deviation for purposes of the public notice and approval requirements set forth in §147(f) of the Internal Revenue Code and §5f.103-2 of the temporary Income Tax Regulations.
This letter is in reply to a request for a ruling that the use of bond proceeds as described below will be an insubstantial deviation from the public notice and approval requirements of §147(f) of the Internal Revenue Code and §5f.103-2(f) of the Temporary Income Tax Regulations.
Reasonable Economic Life:
PLR 200515006 (12/09/2004)
This is in response to the request submitted on behalf of the Issuer for a ruling that the average reasonably expected economic life within the meaning of section 147(b) of the IRC of certain computer software is determined based on all of the issuer's particular facts and circumstances.