Rul. 78-130 particularly troublesome because a triangular C reorganization also could result in unfavorable basis consequences.
Rul. 69-136 was issued, there was in fact a limited exemption for FICA and FUTA tax purposes for stand-by payments made to employees who had attained age 62, if the employee did not work for the employer during the period, if the employment relationship continued to exist, and if the pay was other than vacation or sick pay.
Rul. 2002-62 also clarifies how an individual can satisfy this third safe harbor that tracks the Sec.
Rul. 90-95 that the step-transaction doctrine would not apply to treat a QSP followed by an upstream merger as a taxable asset acquisition, even when the merger occurred under a plan in existence at the time of the acquisition.
Rul. 2002-22 seems to have overturned the IRS rationale found in Field Service Advise 200005006 issued in November 1999.
Rul. 99-7 changed the definition of temporary work location to import the one-year rule from section 162(a) of the Code, resulting in a standard more confusing to apply than the previous standard that a temporary work location was any location at which the taxpayer performed services on an irregular or short-term basis, such as a matter of days or weeks.
Rul. 73-526 explains which EIN may be used by the surviving corporation in certain transactions.
In addition, during the early 1980s, partial liquidations within the context of a consolidated return avoided the recapture
rules of old section 334(b)(2) of the Internal Revenue Code, without jeopardizing a step-up in asset basis from a recent stock purchase.
Rul. 2007-52 concludes that the $1 million liability identified on the proof of claim is an "outstanding liability" for purposes of Sec.
Rul. 96-62 a lump of coal the IRS placed in taxpayers' stockings on December 23rd or is it a nicely wrapped present?
Rul. 88-57 provides guidance concerning the treatment of the repairs conducted pursuant to a program for major cyclical rehabilitation following a predetermined period of use in the taxpayer's business.(20) That ruling, together with the plan-of-rehabilitation doctrine,(21) was cited in a recent technical advice memorandum to require capitalization of routine aircraft engine inspections and overhauls.(22) In addition, the plan-of-rehabilitation doctrine has been cited by agents to deny deductions for the costs of removing equipment (costs of removal) pursuant to a "plan" to install new equipment.
Rul. 2005-48, and concluded that income is recognized for AMT purposes on the exercise date (assuming it is at least six months after the grant date).