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 Related topic Legal Advice Issued by Field Attorneys
