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. 2007 20075201F — Taxation of License AgreementPDF 20075001F — Request for Advice Regarding Allowance of Application for Tentative Refund Based On Claim of Right Adjustment Pursuant to I.R.C. section 1341PDF 20074901F — Gain Recognition Agreements and Reasonable Cause Exceptions under Sec. 367PDF 20074401F — Newspaper Mastheads — Advertiser Accounts — and Subscriber Accounts under Section 1031PDF 20073802F — Advice on the Time for Making the I.R.C. Section 847 ElectionPDF 20073801F — Theft Loss AdvisoryPDF 20073301F — Deductibility of a clawback payment claimed as a royalty paymentPDF 20072502F — Application of Rev. Rul. 89-96 to subject Retroactive Reinsurance TransactionPDF 20072501F — Refund of Sec. 847 Special Estimated Tax Payments (SETP) Paid in Prior YearsPDF 20072201F — Deductibility of 2 1/2% Additional Tax under California Rev. and Tax. Code Sec. 17085PDF 20072101F — Television Network Affiliation Agreement IssuesPDF 20071801F — Tax Treatment of Various Services Related to Environmental Remediation LiabilitiesPDF 20071702F — I.R.C. Section 41(d)(4): Qualified Research; Activities after the beginning of commercial productionPDF 20071701F — Consent to Extend Statute of Limitations on Assessment; Execution of Waiver of Restrictions on AssessmentPDF 20071101F — Valuation of Excess Parts InventoryPDF 20070801F — Issues relating to Agreement to Special LienPDF 20070601F — Application of Rev. Rul. 2001-8 to RebatesPDF 20070401F — Temporary Markdowns Under the Lower-of-Cost-or-Market Inventory MethodPDF 2006 20065101F — Amended return with tax increase and NOL carrybackPDF 20064602F — Form 5471 Filing and Penalty for Failure to FilePDF 20064601F — Worthlessness of partnership interests in and loans toPDF 20064401F — Redemption of StockPDF 20064301F — Calculation of LIFO Index (I.R.C. Sec. 472)PDF 20062801F — Prepayment of Electricity Discounts under Amended Power Purchase AgreementPDF 20062701F — Assertion of penalties for failure to file information returns with respect to certain foreign entitiesPDF 20062201F — PORC Audit IssuesPDF 20061703F — Advice regarding substantial omission and listed transaction exceptions (I.R.C. Sec. 6501)PDF 20061702F — Priority of estate tax lienPDF 20061701F — Vacation and bonus pay employment tax accrualPDF 20060902F — Collection After AssessmentPDF 20060901F — Taxability of Payments to Recipients Under a State FundPDF 2005 20055203F — Deductibility of research and experimental expenditures under I.R.C. § 174PDF 20055202F — Tax treatment of Continued Dumping and Subsidy Offset Act (CDSOA) subsidyPDF 20055201F — Theft Loss AdvisoryPDF 20052501F — Need for a new Form 8655 when EIN merges occurPDF 20051802F — Treatment of Certain LossesPDF 20051801F — Duplicated LossPDF 20051001F — Books and Records Income Allocation Method under I.R.C. § 863PDF 20050203F — Whether the subject sale and acquisition of property qualifies for like-kind exchange treatment under I.R.C. §1031PDF 20050202F — The effect of I.R.C. § 6213(f) on calculations of the last date to file a petition with the Tax Court upon dismissal or discharge from bankruptcy and the statute of limitations date for making an assessment of taxPDF 20050201F — Advisory Opinion on Collection of TaxesPDF Related Topic Legal Advice Issued by Field Attorneys