Internal Revenue Bulletin:  2007-12 

March 19, 2007 

Rev. Rul. 2007-14


Table of Contents

Obsolete revenue rulings. As part of the Service’s continuing program of reviewing previously published guidance, this ruling publishes a list of rulings and actions relating to decisions of the Tax Court that are obsolete. Rev. Rul. 54-19 obsoleted in part. Rev. Ruls. 55-132, 56-462, 56-518, 57-505, 58-370, 58-500, 69-212, and 71-477 obsoleted.

The Internal Revenue Service is continuing its program of reviewing guidance (including revenue rulings, revenue procedures, notices, and actions relating to decisions of the Tax Court) published in the Internal Revenue Bulletin to identify items that are obsolete because (1) the applicable statutory provisions have been changed or repealed; (2) the matter is specifically covered by statute, regulations, or subsequent published position; or (3) the facts on which the position is based no longer occur or are not sufficiently described to permit clear application of the current statute and regulations.

The following revenue ruling is partially obsolete. Rev. Rul. 54-19, 1954-1 C.B. 179, is obsolete with respect to the income tax conclusion, but not with respect to the estate tax conclusion.

In addition, the rulings listed below are obsolete.

Ruling No. C.B. Citation
Rev. Rul. 55-132 1955-1 C.B. 213
Rev. Rul. 56-462 1956-2 C.B. 20
Rev. Rul. 56-518 1956-2 C.B. 25
Rev. Rul. 57-505 1957-2 C.B. 50
Rev. Rul. 58-370 1958-2 C.B. 14
Rev. Rul. 58-500 1958-2 C.B. 21
Rev. Rul. 69-212 1969-1 C.B. 34
Rev. Rul. 71-477 1971-2 C.B. 479

Furthermore, in light of the amendments to § 104(a)(2) of the Internal Revenue Code under § 1605 of the Small Business Job Protection Act of 1996, Pub. L. No. 104-188, 110 Stat. 1838 (1996), certain acquiescences to decisions are obsolete. These amendments make clear that Congress intended “that the exclusion from gross income [under § 104(a)(2)] only applies to damages received on account of a personal physical injury or physical sickness”, and thus damages received on account of personal nonphysical injuries or nonphysical sickness generally would be required to be included in gross income. H.R. Conf. Rep. No. 737, 104th Cong., 2d Sess. 301 (1996), 1996-3 C.B. 1041. Consequently, acquiescences to the following decisions are withdrawn:

Hawkins v. Commissioner, 6 B.T.A. 1023 (1927), acq., VII-1 C.B. 14 (1928).

McDonald v. Commissioner, 9 B.T.A. 1340 (1928), acq., VII-2 C.B. 26 (1928).

DRAFTING INFORMATION

The principal author of this revenue ruling is Christina M. Glendening of the Office of Associate Chief Counsel (Income Tax and Accounting). For further information regarding this revenue ruling, contact Ms. Glendening at (202) 622-4920 (not a toll-free call).


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