The freely available Adobe Acrobat Reader software is required to view, print, and search the rulings and memoranda listed below. Assisted Living Facilities: PLR200038001 PDF This in response to a request for a private letter ruling that the Facility will be a qualified residential rental project for purposes of IRC section 142(d). Exempt Facility Bond Defined: FSA200237016 (05/14/2002) PDF Is the Facility available to serve, on a regular basis, the general public as required by IRC section 142(a)(1) and Treasury Regulation sections 1.103-8(a)(2) and 1.103-8(e)(1)? Is the Facility a directly related and essential part of the Airport, an airport as defined by section 142(a)(1) and section 1.103-8(e)(2)(ii)(a), servicing aircraft or enabling aircraft to take-off and land? FSA200201008 PDF Is the Facility available to serve, on a regular basis, the general public as required by section 142(a)(1) of the Internal Revenue Code and sections 1.103-8(a)(2) and 1.103-8(e)(1)of the Treasury Regulations? Local Furnishing of Electrical Energy and Gas: PLR200340007 (06/27/2003) PDF This letter is in response to a request on behalf of the Issuer and the Holding Company for rulings that (a) SI, a subsidiary of the Holding Company, is a successor in interest to Electric Company for purposes of section 142(f)(3)(B) of the Internal Revenue Code of 1986 and (b) the Facilities will serve or are available on a regular basis for general public use within the meaning of section 1.103-8(a)(2) and 1.103-8(f)(1) of the Income Tax Regulations. PLR200120014 PDF This letter responds to a request on behalf of the Company by a representative for a ruling about whether certain of the Company's facilities will qualify as facilities for "the local furnishing of electric energy" within the meaning of section 142 of the Internal Revenue Code of 1986, as amended (the "1986 Code"), after the transactions described below. PLR200117026 PDF This letter is in response to a request submitted by an authorized representatives for a ruling about the effect on the Bonds of certain aspects of the electric industry restructuring within State. Bondholder is the holder of least one of the Bonds. The Bonds were issued for the benefit of Company. Qualified Residential Rental Project: PLR200345022 (08/04/2003) PDF This is in response to your ruling request under section 142(d) of the Internal Revenue Code of 1986 that certain types of leases of certain units in a residential rent project financed with the Bonds will not cause the Project to be treated as: (1) used on a transient basis under section 1.103-8(b)(4) of the Income Tax Regulations, or (2) unavailable to members of the general public under section 1.103-8(a)(2) for purposes of section 142(d). PLR200306003 (10/02/2002) PDF This is in response to your request for a private letter ruling regarding the applicable qualified project period for the Refunding Bonds. TAM200043015 PDF What costs incurred in the construction of a low-income housing building are included in eligible basis under section 42(d)(1) of the Internal Revenue Code? Specifically, are certain land preparation costs and bond issuance costs incurred by the Taxpayer in constructing the Project included in eligible basis under section 42(d)(1)? TAM200227009 PDF Modifies TAM200043016 TAM200043016 PDF What costs incurred in the construction of a low-income housing building are included in eligible basis under section 42(d)(1) of the Internal Revenue Code? Specifically, are local impact fees, certain land preparation costs, construction loan costs, and certain contractor fees incurred by the Taxpayer in constructing the Project included in eligible basis under section 42(d)(1)? Solid Waste Disposal Facility: TAM 200452034 (10/01/2004) PDF Whether spent fuel rods are solid waste within the meaning of section 142(a)(6) of the Internal Revenue Code. PLR200226002 (03/01/2002) PDF This letter is in response to your request for a ruling that the Project constitutes a solid waste disposal facility within the meaning of section 142(a)(6) of the Code. FSA200207010 (11/08/2001) PDF Was the bond-financed facility a "qualified hazardous waste facility", as defined in section 142(a)(10) of the Internal Revenue Code? Can a facility, which processes hazardous waste, qualify as a "solid waste disposal facility", as defined in section 142(a)(6)? Did the conduit borrower spend bond proceeds on a qualified exempt facility pursuant to section 142(a)? PLR200146043 PDF This responds to the State's request for the following two rulings: The State's proposed use of proceeds of the Bonds (a use that if tested separately, would not meet §141(a) of the Internal Revenue Code of 1986) will not cause less than 95 percent of the net proceeds of the Bonds to be used to provide an exempt facility under §142(a). The proposed use of the proceeds of the Bonds will not cause §147(f) to be violated. TAM199918001 PDF Whether the permanent bonds issued by City to fund the construction by Operator of a facility (the "Facility") to recycle into qualify as exempt facility bonds under §142(a) of the Internal Revenue Code.
