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.
2011
- 20115101F — Temporary Taking of Two Properties Attributable to an Involuntary Conversion PDF
- 20115001F — Non-deductibility of Certain Corporate Costs PDF
- 20114901F — Attorney Fees Incurred to Defend Against Patent Infringement Claims and to Investigate Patents PDF
- 20114704F — Conversion of Penalty Portion of Settlement Allocation in Class Action Lawsuit to Wages PDF
- 20114703F — Cost Recovery of Capitalized Attorney Fees Incurred to Defend Against Patent Infringement Claims and to Investigate Patents PDF
- 20114702F — LIFO Conformity Violation PDF
- 20114701F — Examination of Previously examined Year in Connection with Net Operating Loss Carryback PDF
- 20113901F — Qualifying Small Power Production Facility PDF
- 20113802F — Income Recognition from Sales of Gift Checks by a Membership Special Entity PDF
- 20113801F — Contribution of Inventory Approaching "best by" Date PDF
- 20112701F — Bank Enterprise Award payment received from the U.S. Department of the Treasury Community Development Financial Institutions Fund PDF
- 20111701F — Tax Matters Partner's Authority to Sign a Form 872-P PDF
- 20111101F — Deductibility of Purportedly Worthless Goodwill PDF
2010
- 20105101F — Retroactive Re-classification of Purchases into PURPIMS PDF
- 20105001F — Foreign Tax Credit PDF
- 20103901F — Graduate Level Tuition Waivers as Taxable Fringe Benefits PDF
- 20103101F — Patronage Dividend Deduction PDF
- 20103002F — Income Tax Adjustment for Certain Payments or Discounts made in Violation of the Anti-Kickback Act — 41 U.S.C. sections 51-58 PDF
- 20103001F — TEFRA Partnership Issues PDF
- 20102901F — Request for Legal Advice on Procedures when Dealing with Frivolous Business Returns PDF
- 20102602F — Application of Uniform Capitalization Rules of Section 263A to Ending Physical Grain Inventory Held for Resale PDF
- 20102601F — Wrongful Levy PDF
- 20101502F — I.R.C. Section 833(b) Special Deduction PDF
- 20101501F — Housing Authority Mutual Help Homeownership Opportunity Program PDF
- 20100902F — I.R.C. Section 482 Acquisition Buy-in PDF
- 20100901F — Use of Gift Card Disregarded Entity PDF
- 20100502F — Use of Tax Book Value to Establish Fair Market Value of Assets PDF
- 20100501F — Effect of Closing Agreement on Taxpayer's LIFO Definition of an Item PDF
- 20100301F — Tax Treatment of Post-Spinoff Payments PDF