These documents are prepared by field attorneys in the Office of Chief Counsel, reviewed by an Associate Office, and subsequently issued to field or service center campus employees of the Internal Revenue Service. Note: These items cannot be used or cited as precedent. 2013 20134901F — Gain or loss from the sale of securities reported on Forms 1120-SFPDF 20134801F — Deferral of Income Recognition for Contracts for the Sale of GoodsPDF 20133901F — Amortization of Player ContractsPDF 20133702F — Section 6404(g)PDF 20133701F — Section 833(b) Special DeductionPDF 20133501F — Reporting Requirements for Attorney's Fee PaidPDF 20133303F — Application of Section 6702 Penalty to TaxpayerPDF 20133302F — Section 199 Claim for Photo Processing ActivitiesPDF 20133301F — Validity of Closing AgreementPDF 20133101F — Whether taxpayer is entitled to a deduction for abandonment lossesPDF 20132801F — Deduction for Indemnification of LiabilityPDF 20132702F — Whether sales from selling/licensing software are foreign base company incomePDF 20132701F — Deduction Against Nonpatronage - Sourced IncomePDF 20132101F — Whether holdings is a continuation of TaxpayerPDF 20131902F — Treasury Regulation 1.246-5(c)(6) Use of related persons or pass-through entitiesPDF 20131901F — Character of Gain on Sale of Merchant ContractsPDF 20131802F — Aggregation of Patronage and Non-Patronage Sourced ActivitiesPDF 20131801F — Worker Classification IssuePDF 20131701F — SPV Financing TransactionPDF 20131601F — Majority ShareholderPDF 20131201F — Amortization of PatentsPDF 20131102F — Treatment of Voluntary Separation Payments under IRC § 41PDF 20131101F — Authority to Sign Form 870-LTPDF 20131001F — Capitalization of Litigation Fees IncurredPDF 20130501F — I.R.C. § 162PDF 20130101F — Gross Income and Grants to RailroadsPDF 2012 20125202F — Foreign Tax CreditPDF 20125201F — Analysis of Negligence Penalty and Reasonable Basis under IRC § 6662PDF 20124801F — Like-Kind ExchangePDF 20124701F — Whether the Mitigation Provisions contained in IRC Sections 1311 to 1314 ApplyPDF 20124603F — Whether Taxpayer is entitled to a claimed abandonment lossPDF 20124602F — Form 1099 Requirements for ClaimsPDF 20124601F — Transitory Corporations and I.R.C. section 351PDF 20124402F — Form 1099 Requirements for ClaimsPDF 20124401F — Capitalization of minimum royalties under section 263APDF 20124201F — Responses to Attorney LetterPDF 20124103F — Income from Discharge of IndebtednessPDF 20124102F — Request for MitigationPDF 20124101F — Refund with respect to the carryback of CNOLPDF 20124002F — Rehabilitation Tax Credit IssuePDF 20124001F — Comparability Adjustments under § 482PDF 20123905F — Refund ClaimPDF 20123904F — Authority to Sign Form 870-LTPDF 20123903F — Rebuttal to Taxpayer's ProtestPDF 20123902F — Acceptance of 5 year carryback electionPDF 20123901F — Application of the Attorney-Client Privilege to Corporate MinutesPDF 20123801F — Taxpayers Amended ReturnPDF 20123401F — Application of Judicial Doctrines to Monetization TransactionPDF 20123201F — Application of Section 263A to OREO propertyPDF 20123002F — Bad Debt DeductionPDF 20123001F — Taxation of Commercialization AgreementPDF 20121701F — Gain RecognitionPDF 20121602F — Deduction for Chargeback Reimbursement Accrued ExpensePDF 20121601F — Research Credit -- Excluded Activities Funded ResearchPDF 20121501F — Application of Mitigation RulesPDF 20121401F — Research Credit – Excluded Activities Funded ResearchPDF 20121202F — Holding Period Requirement for Dividends-Received DeductionPDF 20121201F — Holding Period Requirement for Dividends-Received DeductionPDF Related Topic Legal Advice Issued by Field Attorneys