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.
2015
- 20154703F — Hedging Transaction PDF
- 20154702F — Payment to Foreign Government PDF
- 20154701F — Determination of Amount of and Recognition of Gain or Loss PDF
- 20154601F — I.R.C. § 168 – Loss on Disposition of Building Structural Components PDF
- 20154502F — Legal Fees Incurred to Create an FDA-Approved ANDA PDF
- 20154501F — Determination of Reasonable Compensation for purposes of I.R.C sections 162 & 174 PDF
- 20153901F — Form 2848 review – Part II PDF
- 20153601F — Question Regarding Multiple Buy-ins to Poker Tournament PDF
- 20153501F — Bad Debts PDF
- 20152201F — I.R.C. Section 6501(c)(9) Exception to Statute of Limitations PDF
- 20153301F — Intercompany Referral Fees PDF
- 20153101F — Treatment of Expenses Incurred on Behalf of Joint Venture PDF
- 20153001F — Reporting and Payment of LIFO Recapture PDF
- 20152302F — Failure to Honor Levy PDF
- 20152301F — Service Reliance on a Consent PDF
- 20152104F — Disposition under I.R.C. Section 367(d) PDF
- 20152103F — Deductibility of Payment Under FDA Consent Decree PDF
- 20152102F — Payments for Negative Easements PDF
- 20152101F — Form 941 — Form 944 — and the Period of Limitations PDF
- 20151704F — Application of Sections 1.263(a)-4 and 5 to Consent Payment PDF
- 20151703F — Claim for Refund: Federal Telephone Excise Tax PDF
- 20151702F — Section 382 PDF
- 20151701F — I.R.C. §§ 382 and 482 PDF
- 20151601F — Railroad Track Maintenance Credit Computation PDF
- 20151201F — Exchangeable Debentures PDF
- 20151002F — Requirement to File Information Returns Under IRC section 6041 and/or 6045 PDF
- 20151001F — Alternative Fuel Mixture Credit PDF
- 20150801F — PURPIM under IRC section 1388(f) PDF
- 20150701F — Deductibility of Unreimbursed Expenses PDF
- 20150601F — Review of FASIT Transaction PDF
- 20150301F — Application of SRLY Provisions PDF
2014
- 20145102F — Costless Collar Transaction PDF
- 20145101F — Capitalization of Royalties – 263A COGS PDF
- 20145001F — Application of TEFRA to Employment Tax Examinations PDF
- 20144801F — Characterization of Amounts Received on the Sale of I.R.C. Section 166 Impaired Real Estate Mortgage Investment Conduit Regular Interests PDF
- 20144702F — Inclusion of Funding Agreement Interest in Policy Interest PDF
- 20144701F — Acquiring Corporation's Use of Target's Pre-Acquisition Qualified Research Expenses PDF
- 20144601F — Extended Five-Year Carryback of Net Operating Losses from Operations PDF
- 20144201F — Alternative Tax Net Operating Loss Absorption Rules PDF
- 20141001F — Deductibility of Payment of Underwriting Costs PDF
- 20141002F — Section 172(f)(1) Rebuttal PDF
- 20140202F — Whether Taxpayer is Entitled to Bonus Depreciation PDF
- 20140201F — Treatment of Premium Stabilization Reserves PDF