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 ConversionPDF 20115001F — Non-deductibility of Certain Corporate CostsPDF 20114901F — Attorney Fees Incurred to Defend Against Patent Infringement Claims and to Investigate PatentsPDF 20114704F — Conversion of Penalty Portion of Settlement Allocation in Class Action Lawsuit to WagesPDF 20114703F — Cost Recovery of Capitalized Attorney Fees Incurred to Defend Against Patent Infringement Claims and to Investigate PatentsPDF 20114702F — LIFO Conformity ViolationPDF 20114701F — Examination of Previously examined Year in Connection with Net Operating Loss CarrybackPDF 20113901F — Qualifying Small Power Production FacilityPDF 20113802F — Income Recognition from Sales of Gift Checks by a Membership Special EntityPDF 20113801F — Contribution of Inventory Approaching "best by" DatePDF 20112701F — Bank Enterprise Award payment received from the U.S. Department of the Treasury Community Development Financial Institutions FundPDF 20111701F — Tax Matters Partner's Authority to Sign a Form 872-PPDF 20111101F — Deductibility of Purportedly Worthless GoodwillPDF 2010 20105101F — Retroactive Re-classification of Purchases into PURPIMSPDF 20105001F — Foreign Tax CreditPDF 20103901F — Graduate Level Tuition Waivers as Taxable Fringe BenefitsPDF 20103101F — Patronage Dividend DeductionPDF 20103002F — Income Tax Adjustment for Certain Payments or Discounts made in Violation of the Anti-Kickback Act — 41 U.S.C. sections 51-58PDF 20103001F — TEFRA Partnership IssuesPDF 20102901F — Request for Legal Advice on Procedures when Dealing with Frivolous Business ReturnsPDF 20102602F — Application of Uniform Capitalization Rules of Section 263A to Ending Physical Grain Inventory Held for ResalePDF 20102601F — Wrongful LevyPDF 20101502F — I.R.C. Section 833(b) Special DeductionPDF 20101501F — Housing Authority Mutual Help Homeownership Opportunity ProgramPDF 20100902F — I.R.C. Section 482 Acquisition Buy-inPDF 20100901F — Use of Gift Card Disregarded EntityPDF 20100502F — Use of Tax Book Value to Establish Fair Market Value of AssetsPDF 20100501F — Effect of Closing Agreement on Taxpayer's LIFO Definition of an ItemPDF 20100301F — Tax Treatment of Post-Spinoff PaymentsPDF Related Topic Legal Advice Issued by Field Attorneys
