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. 2013 20134901F — Gain or loss from the sale of securities reported on Forms 1120-SF PDF 20134801F — Deferral of Income Recognition for Contracts for the Sale of Goods PDF 20133901F — Amortization of Player Contracts PDF 20133702F — Section 6404(g) PDF 20133701F — Section 833(b) Special Deduction PDF 20133501F — Reporting Requirements for Attorney's Fee Paid PDF 20133303F — Application of Section 6702 Penalty to Taxpayer PDF 20133302F — Section 199 Claim for Photo Processing Activities PDF 20133301F — Validity of Closing Agreement PDF 20133101F — Whether taxpayer is entitled to a deduction for abandonment losses PDF 20132801F — Deduction for Indemnification of Liability PDF 20132702F — Whether sales from selling/licensing software are foreign base company income PDF 20132701F — Deduction Against Nonpatronage - Sourced Income PDF 20132101F — Whether holdings is a continuation of Taxpayer PDF 20131902F — Treasury Regulation 1.246-5(c)(6) Use of related persons or pass-through entities PDF 20131901F — Character of Gain on Sale of Merchant Contracts PDF 20131802F — Aggregation of Patronage and Non-Patronage Sourced Activities PDF 20131801F — Worker Classification Issue PDF 20131701F — SPV Financing Transaction PDF 20131601F — Majority Shareholder PDF 20131201F — Amortization of Patents PDF 20131102F — Treatment of Voluntary Separation Payments under IRC § 41 PDF 20131101F — Authority to Sign Form 870-LT PDF 20131001F — Capitalization of Litigation Fees Incurred PDF 20130501F — I.R.C. § 162 PDF 20130101F — Gross Income and Grants to Railroads PDF 2012 20125202F — Foreign Tax Credit PDF 20125201F — Analysis of Negligence Penalty and Reasonable Basis under IRC § 6662 PDF 20124801F — Like-Kind Exchange PDF 20124701F — Whether the Mitigation Provisions contained in IRC Sections 1311 to 1314 Apply PDF 20124603F — Whether Taxpayer is entitled to a claimed abandonment loss PDF 20124602F — Form 1099 Requirements for Claims PDF 20124601F — Transitory Corporations and I.R.C. section 351 PDF 20124402F — Form 1099 Requirements for Claims PDF 20124401F — Capitalization of minimum royalties under section 263A PDF 20124201F — Responses to Attorney Letter PDF 20124103F — Income from Discharge of Indebtedness PDF 20124102F — Request for Mitigation PDF 20124101F — Refund with respect to the carryback of CNOL PDF 20124002F — Rehabilitation Tax Credit Issue PDF 20124001F — Comparability Adjustments under § 482 PDF 20123905F — Refund Claim PDF 20123904F — Authority to Sign Form 870-LT PDF 20123903F — Rebuttal to Taxpayer's Protest PDF 20123902F — Acceptance of 5 year carryback election PDF 20123901F — Application of the Attorney-Client Privilege to Corporate Minutes PDF 20123801F — Taxpayers Amended Return PDF 20123401F — Application of Judicial Doctrines to Monetization Transaction PDF 20123201F — Application of Section 263A to OREO property PDF 20123002F — Bad Debt Deduction PDF 20123001F — Taxation of Commercialization Agreement PDF 20121701F — Gain Recognition PDF 20121602F — Deduction for Chargeback Reimbursement Accrued Expense PDF 20121601F — Research Credit -- Excluded Activities Funded Research PDF 20121501F — Application of Mitigation Rules PDF 20121401F — Research Credit – Excluded Activities Funded Research PDF 20121202F — Holding Period Requirement for Dividends-Received Deduction PDF 20121201F — Holding Period Requirement for Dividends-Received Deduction PDF Related topic Legal Advice Issued by Field Attorneys
