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IRC Section 451 - PLR

 

Private letter rulings - IRC Section 451
Issue PLR Number
Whether the Tribe will be treated as the owner of Trust under section 676 because the Tribe and nonadverse parties may terminate Trust and revest the assets in the Tribe. Furthermore, whether the Tribe, which is not subject to federal income tax, shall not be subject to federal income tax on the income of the Trust.

PLR-200209015 PDF

11/26/2001