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 TransactionPDF 20154702F — Payment to Foreign GovernmentPDF 20154701F — Determination of Amount of and Recognition of Gain or LossPDF 20154601F — I.R.C. § 168 – Loss on Disposition of Building Structural ComponentsPDF 20154502F — Legal Fees Incurred to Create an FDA-Approved ANDAPDF 20154501F — Determination of Reasonable Compensation for purposes of I.R.C sections 162 & 174PDF 20153901F — Form 2848 review – Part IIPDF 20153601F — Question Regarding Multiple Buy-ins to Poker TournamentPDF 20153501F — Bad DebtsPDF 20152201F — I.R.C. Section 6501(c)(9) Exception to Statute of LimitationsPDF 20153301F — Intercompany Referral FeesPDF 20153101F — Treatment of Expenses Incurred on Behalf of Joint VenturePDF 20153001F — Reporting and Payment of LIFO RecapturePDF 20152302F — Failure to Honor LevyPDF 20152301F — Service Reliance on a ConsentPDF 20152104F — Disposition under I.R.C. Section 367(d)PDF 20152103F — Deductibility of Payment Under FDA Consent DecreePDF 20152102F — Payments for Negative EasementsPDF 20152101F — Form 941 — Form 944 — and the Period of LimitationsPDF 20151704F — Application of Sections 1.263(a)-4 and 5 to Consent PaymentPDF 20151703F — Claim for Refund: Federal Telephone Excise TaxPDF 20151702F — Section 382PDF 20151701F — I.R.C. §§ 382 and 482PDF 20151601F — Railroad Track Maintenance Credit ComputationPDF 20151201F — Exchangeable DebenturesPDF 20151002F — Requirement to File Information Returns Under IRC section 6041 and/or 6045PDF 20151001F — Alternative Fuel Mixture CreditPDF 20150801F — PURPIM under IRC section 1388(f)PDF 20150701F — Deductibility of Unreimbursed ExpensesPDF 20150601F — Review of FASIT TransactionPDF 20150301F — Application of SRLY ProvisionsPDF 2014 20145102F — Costless Collar TransactionPDF 20145101F — Capitalization of Royalties – 263A COGSPDF 20145001F — Application of TEFRA to Employment Tax ExaminationsPDF 20144801F — Characterization of Amounts Received on the Sale of I.R.C. Section 166 Impaired Real Estate Mortgage Investment Conduit Regular InterestsPDF 20144702F — Inclusion of Funding Agreement Interest in Policy InterestPDF 20144701F — Acquiring Corporation's Use of Target's Pre-Acquisition Qualified Research ExpensesPDF 20144601F — Extended Five-Year Carryback of Net Operating Losses from OperationsPDF 20144201F — Alternative Tax Net Operating Loss Absorption RulesPDF 20141001F — Deductibility of Payment of Underwriting CostsPDF 20141002F — Section 172(f)(1) RebuttalPDF 20140202F — Whether Taxpayer is Entitled to Bonus DepreciationPDF 20140201F — Treatment of Premium Stabilization ReservesPDF Related Topic Legal Advice Issued by Field Attorneys